Rajasthan High CourtConstitutional LawEducation Law

Reservation benefits are state-specific and cannot be extended to reserved category candidates migrating from other states.

FEDERATION OF PRIVATE MEDICAL AND DENTAL COLLEGE OF RAJASTHANv.CHAIRMAN

Reservation benefits are state-specific and cannot be extended to reserved category candidates migrating from other states.. FEDERATION OF PRIVATE MEDICAL AND DENTAL COLLEGE OF RAJASTHAN vs CHAIRMAN. Rajasthan High Court. LawLens
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In brief

The question

1. Whether the denial of reservation benefits (specifically the reduced qualifying percentile) to candidates belonging to reserved categories from other states is arbitrary or violative of the constitutional mandate

The court held

The Court dismissed the writ petition, holding that the impugned decision was legally sound

It also directed

(i) reservation benefits are restricted to the state of origin and cannot be extended to migrants; (ii) the policy does not amount to 100% domicile reservation as out-of-state candidates may still compete in the General category; and (iii) it is legally impermissible for candidates to claim a "reserved" relaxed percentile for "unreserved" seats.

The court found no illegality or arbitrariness in the Respondent's actions

01Facts

The Petitioner, a federation of private colleges, challenged the minutes of a meeting dated 18.02.2026 issued by the Rajasthan NEET PG Admission Board

p. 2

Following the NEET PG 2025-2026 exams, the Central Government lowered the qualifying percentile to fill vacant seats; for instance, the General category cut-off dropped to 103 and the SC/ST/OBC cut-off dropped to -40

p. 4

The Respondent authorities decided that reserved category candidates from other states (non-domiciles of Rajasthan) would be treated as General category candidates and must meet the General cut-off (103) rather than the relaxed reserved cut-off (-40) to participate in the stray vacancy round

p. 5

The Petitioner argued this constituted illegal 100% domicile-based reservation and resulted in national wastage of medical seats

pp. 5-6

02Issues

i.1. Whether the denial of reservation benefits (specifically the reduced qualifying percentile) to candidates belonging to reserved categories from other states is arbitrary or violative of the constitutional mandate

p. 10

ii.2. Whether the impugned decision results in an impermissible 100% reservation based on domicile

p. 10

iii.3. Whether reserved category candidates of other states should be permitted to participate against unreserved seats while availing the benefit of the relaxed percentile prescribed for reserved categories

p. 21

03Law Applied

The court primarily relied on the state-specific nature of reservation under Articles 341, 342, and 342A of the Constitution of India, which specify that Scheduled Castes and Tribes are deemed so "in relation to that State"

pp. 11-12

It applied the precedent from Marri Chandra Shekhar Rao v. Seth G.S. Medical College, which held that a person notified as a reserved category member in one state cannot claim that status in another state upon migration.

p. 14

This was supported by Bir Singh v. Delhi Jal Board [p. 15] and Ranjana Kumari v. State of Uttarakhand [p. 17]. Furthermore, the court referred to the Rajasthan Act of 2008 and the Postgraduate Medical Education Regulations, 2023 (Clause 4.8), which mandate that reservation follow state-specific laws

pp. 12-13, 15, 17

Provisions in the judgment · 2 · Linked ones open on LawLens

RAJASTHAN SCHEDULED CASTES, SCHEDULED TRIBES, BACKWARD CLASSESS, SPECIAL BACKWARD CLASSES AND ECONOMICALLY BACKWARD CLASSES (RESERVATION OF SEATS IN EDUCATIONL INSTITUTIONS IN THE STATE AND OF APPOINTMENTS AND POSTS IN SERVICES UNDER THE STATE) ACT, 2008 Section 2Section 3

04Reasoning

The court reasoned that since the Presidential Orders for SC/ST/OBC status are geographically confined to specific states, the benefits of reservation—including relaxed eligibility criteria—cannot be carried across state borders

p. 13, 16

The court found that Clause 4 of the State’s Instruction Booklet, which restricted reservation benefits to "bonafide candidates of Rajasthan," was consistent with this constitutional scheme

pp. 17-18

Regarding the "100% domicile" argument, the court observed that out-of-state reserved candidates were not barred from admission; they were simply required to compete in the General category using General category qualifying marks

p. 19

The court rejected the Petitioner's claim that relaxed standards should apply to out-of-state candidates competing for unreserved seats, stating that once a seat is treated as "unreserved" due to the exhaustion of the local reserved list, any candidate seeking it must meet the General category threshold to maintain the integrity of the selection process

pp. 20-21

The court noted that while filling seats is important, it cannot override minimum merit standards or the statutory framework

p. 22

05Holding

The Court dismissed the writ petition, holding that the impugned decision was legally sound

p. 26

(i) reservation benefits are restricted to the state of origin and cannot be extended to migrants; (ii) the policy does not amount to 100% domicile reservation as out-of-state candidates may still compete in the General category; and (iii) it is legally impermissible for candidates to claim a "reserved" relaxed percentile for "unreserved" seats.

¶ 16(i), 16(ii), 16(iii)

The court found no illegality or arbitrariness in the Respondent's actions

p. 26
Rajasthan High Court

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FEDERATION OF PRIVATE MEDICAL AND DENTAL COLLEGE OF RAJASTHANvsCHAIRMAN

Rajasthan High Court · April 13, 2026

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