Courts cannot expand statutory admission exemptions to include categories omitted by the governing rules.

The petitioner, born in Gandhinagar and claiming Gujarat domicile, passed Standard X from a CBSE school in New Delhi in 2024 while residing there with her father, an employee of the National Technical Research Organisation (NTRO), Government of India. She subsequently completed Standards XI and XII in Gujarat and passed the Gujarat Board HSC examination in 2026. After securing 513 marks in NEET-UG 2026, she applied for admission to MBBS courses under the Gujarat State Quota.

Her candidature was placed in the “Not Eligible Candidate List” because she had passed Standard X from a school outside Gujarat, despite her Gujarat domicile, birth in Gujarat and subsequent education in the State.

She challenged the rejection and sought an interpretation or reading down of Rule 4(6) of the Gujarat Professional Medical Educational Courses (Regulation of Admission in Undergraduate Courses) Rules, 2017, so as to include children of Central Government employees posted outside Gujarat.

She relied, inter alia, on the fact that NTRO is an intelligence organisation connected with national security and argued that her circumstances were analogous to those of children of defence or paramilitary personnel.

The State opposed the petition, contending that NTRO personnel are not defence personnel and that the Court could not enlarge the express categories in Rule 4(6).

Whether the petitioner, having passed Standard X from a school outside Gujarat but Standards XI and XII in Gujarat, satisfied the eligibility requirement under Rule 4(3) for admission under the Gujarat State Quota.

Whether the petitioner, as the daughter of an NTRO employee posted outside Gujarat, fell within the expression “sons and daughters of defence personnel” under Rule 4(6)(c) of the 2017 Rules.

Whether Rule 4(6) could be read down or expanded under Article 14 to include Gujarat-domiciled candidates whose schooling outside the State resulted from the compulsory transferable service of a Central Government employee parent.

Whether the petitioner was entitled to a direction permitting her to participate in the Gujarat State Quota admission process for the academic year 2026–27.

Rule 4(3) of the Gujarat Professional Medical Educational Courses (Regulation of Admission in Undergraduate Courses) Rules, 2017 requires candidates seeking State Quota admission to have passed the qualifying examinations from the specified Boards, with the school located in Gujarat in the case of CBSE and other specified Boards.

Rule 4(6) creates limited exceptions for children of specified categories, namely All India Services officers allotted to Gujarat and serving outside the State, Gujarat Government employees posted outside Gujarat for administrative reasons, defence personnel domiciled in Gujarat and serving outside Gujarat, and paramilitary personnel domiciled in Gujarat and serving outside Gujarat.

Applying Vishakha D/o Mahendra Patel v. State of Gujarat & Anr. , LPA No. 921 of 2012, and the principles stated in State of Madhya Pradesh v. Rakesh Kohli , Mohd. Hanif Quareshi v. State of Bihar and related authorities, the Court held that legislation is presumed constitutional, courts cannot enlarge a statutory classification merely because another classification may appear more appropriate, and legislative inclusion of an additional category cannot be undertaken through writ jurisdiction.

The Court distinguished Vansh S/o Prakash Dolas v. Ministry of Education , 2024 (20) SCC 306, where a Maharashtra admission rule was read down because of an irrational distinction between Government of India employees posted inside and outside Maharashtra.

The Court held that the petitioner did not satisfy Rule 4(3), since she had passed Standard X from New Delhi and therefore did not meet the requirement that the relevant schooling be undertaken in Gujarat.

It further found that NTRO, although an intelligence and highly sensitive organisation, functions under the Ministry of Home Affairs and could not be treated as a defence service for purposes of Rule 4(6)(c); the materials relied upon by the petitioner showed coordination with, rather than identity with, defence, paramilitary and law-enforcement agencies.

The Court emphasised that the petitioner had not challenged the constitutional validity of Rules 4(3) or 4(6); consequently, there was no basis to read down the provisions to create an additional exception for children of Central Government employees generally.

Extending Rule 4(6)(c) to NTRO personnel would effectively amend the Rule and amount to judicial legislation, a function reserved for the competent rule-making authority.

Vansh Dolas was distinguished because the Gujarat Rules contained no comparable provision or distinction warranting the same interpretive remedy.

The prayers to quash the “Not Eligible Candidate List,” declare the petitioner eligible for the Gujarat State Quota, and permit her participation in the 2026–27 admission process were rejected. The Special Civil Application was dismissed, with no order as to costs.