DATE: 07/01/2022
BENCH: Justice Dr D.Y. Chandrachud and Justice A.S. Bopanna
FACTS:
The case of arose from a challenge to the implementation of Other Backward Classes (OBC) and Economically Weaker Sections (EWS) reservations in the All India Quota (AIQ) seats for medical postgraduate and undergraduate admissions. The AIQ scheme was introduced to ensure uniform distribution of medical seats across the country, reserving 15% of undergraduate (MBBS) and 50% of postgraduate (MD/MS) seats in government medical colleges for candidates from other states. Until 2021, there was no reservation for OBC and EWS categories in the AIQ seats for medical colleges, despite reservations being applied in state quota admissions. In July 2021, the Union Government announced a 27% OBC and 10% EWS reservation in AIQ medical seats, bringing AIQ reservations in line with the existing state policies. However, this decision was challenged in the Supreme Court, with petitioners arguing that such reservations violated merit-based admissions and constitutional provisions.
The primary petitioners, including Neil Aurelio Nunes, contended that the inclusion of OBC and EWS reservations in AIQ seats diluted merit-based selection and was contrary to previous judicial rulings, which had emphasized limited reservations in AIQ to prevent excessive compartmentalization of seats. Additionally, the petitioners questioned the methodology used to determine EWS eligibility, particularly the ₹8 lakh annual income criterion. They argued that this income cap lacked empirical justification and disproportionately included economically stable individuals, undermining the purpose of the reservation. In response, the Union Government defended the reservation policy, asserting that it aligned with constitutional mandates and upheld the principle of social justice. The case eventually reached the Supreme Court, which had to determine the constitutionality and validity of the OBC and EWS reservations in AIQ medical admissions.
ISSUES:
The case challenged the 27% OBC and 10% EWS reservations in All India Quota (AIQ) medical admissions. Key issues included whether OBC reservations in AIQ violated merit-based selection and judicial precedents and whether the ₹8 lakh EWS income threshold was arbitrary. The Supreme Court had to determine if these reservations aligned with constitutional principles of equality, merit, and affirmative action.
JUDGEMENT WITH REASONIG:
The Supreme Court upheld the 27% reservation for OBCs and 10% reservation for EWS in All India Quota (AIQ) medical admissions, affirming that reservation is not against merit but a tool for achieving social justice. The Court ruled that the OBC reservation is constitutionally valid, acknowledging the need for equitable representation in medical education. However, it allowed the ₹8 lakh income criterion for EWS reservations to apply for the current academic year but directed the government to reassess the threshold for future admissions. The judgment reinforced the principle that merit must be viewed in the context of social and economic barriers rather than solely as individual academic performance.
The Supreme Court reasoned that reservation is an instrument of social justice and not contrary to meritocracy. It emphasized that merit cannot be defined solely by exam scores but must consider structural disadvantages faced by historically marginalized communities. The Court recognized that OBCs have been underrepresented in higher education and professional fields, justifying their 27% reservation in the All India Quota (AIQ) for medical admissions. It also rejected the argument that reservations should be confined to initial education levels, affirming that access to higher education, including professional courses, is crucial for social upliftment.
Regarding the 10% reservation for Economically Weaker Sections (EWS), the Court held that economic criteria alone can be a basis for affirmative action but required the ₹8 lakh annual income limit to be re-examined for future admissions. It allowed the existing criteria to be used for the current academic year to prevent disruptions but instructed the government to conduct a detailed study on the appropriate threshold. The judgment reinforced that reservation policies must be tailored to promote substantive equality, ensuring historically and economically disadvantaged groups can compete fairly in higher education and professional opportunities.
ANALYSIS:
The Supreme Court’s ruling in Neil Aurelio Nunes v. Union of India reaffirmed the constitutional validity of reservations as a necessary tool for achieving substantive equality in medical education. By upholding the 27% OBC reservation, the Court recognized the persistent underrepresentation of socially and educationally disadvantaged groups in higher education and professional fields. It emphasized that merit must be viewed holistically, accounting for historical inequalities rather than being narrowly defined by exam scores. The judgment reinforced the idea that affirmative action in AIQ seats was a logical extension of state-level reservations and did not violate merit-based principles. Additionally, by linking social justice with equitable representation, the Court ensured that reservations in medical education were aligned with constitutional mandates.
On the issue of EWS reservations, the Court took a balanced approach. While it upheld the concept of economic-based reservation, it acknowledged concerns over the arbitrariness of the ₹8 lakh income threshold. Recognizing the need for empirical justification, the Court allowed the income cap for the current academic year but directed the government to conduct a thorough review for future implementation. This reflects the Court’s effort to balance policy continuity with constitutional scrutiny, ensuring that reservations benefit genuinely disadvantaged individuals. The judgment sets a precedent for evaluating reservation policies through empirical assessment rather than arbitrary economic benchmarks, reinforcing the importance of rational, data-driven policymaking in affirmative action schemes.
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