Madras High Court Upholds Government Quota in PG Medical Seats for Minority Institutions

The Madras High Court has reaffirmed the applicability of the Postgraduate Medical Education Regulations (PGMER), 2023, to private linguistic minority medical colleges, ruling that such institutions are obligated to reserve a portion of their postgraduate (PG) medical seats for the government quota. The decision follows the dismissal of a plea filed by Venkateshwara Medical College and Research Centre, Puducherry, which sought to exempt all its PG medical seats from government allocation.

The college had challenged a notification issued by the Puducherry Government on July 22, 2024, mandating the surrender of 50% of its PG seats for the government quota. It was argued by the petitioner that all its PG seats should be categorized under the All India Management Quota, allowing the institution full control over the admissions process.

The petitioner contended that PGMER 2023, unlike its predecessor from 2000, does not explicitly require the reservation of government quota seats. Additionally, the college referred to Clause 4.8 of PGMER 2023, which mandates that seat reservation must align with the laws of the respective state or union territory. It was further claimed that the Puducherry Government’s regulations on admissions, framed in 2006, exempt minority institutions from adhering to seat reservation policies under Article 30(1) of the Constitution of India.

In response, the National Medical Commission (NMC) and the Puducherry Government emphasized the binding nature of the agreements signed by the institution at its inception. The government’s counsel highlighted that the college had committed to sharing 50% of its seats with the government at the time of its establishment in compliance with the essentiality certificate requirements. Furthermore, Clause 4.8 of PGMER 2023 was cited to reinforce the government’s authority to implement its reservation policy, regardless of the institution’s minority status.

The High Court bench rejected the petitioner’s argument that the agreement with the government was limited to undergraduate (UG) seats. The bench clarified that the agreement included postgraduate seats, as evidenced by its terms. The petitioner’s attempt to treat all PG seats as management quota seats was deemed impermissible, with the court emphasizing that Article 30 of the Constitution grants minorities the right to establish and administer educational institutions but does not confer any special privileges.

The court further stated that treating all PG seats as management quota would amount to granting undue privilege to the institution, which is not permissible under the Constitution. It was observed that the judiciary could enforce rights but could not create privileges that extend beyond the scope of constitutional provisions.

While dismissing the plea, the bench acknowledged the need to prevent wastage of seats in cases where minority quota seats remain unfilled. The court suggested that a conversion process could be undertaken to utilize such seats, provided it aligns with existing legal frameworks.

Relying on prior rulings by the Supreme Court, the High Court concluded that the petitioner college was not entitled to any relief. The decision upholds the Puducherry Government’s notification and reinforces the principle that minority institutions must adhere to regulations and agreements concerning seat allocation.

(Input from various sources)

(Rehash/Ankur Deka/MSM)