OVER-CENTRALISATION THREATENS FEDERAL HEALTH POLICY
Why in the News?
- The Supreme Court, in the case Tanvi Behl vs Shrey Goyal (2025), has struck down domicile-based reservations in post-graduate medical admissions.
- The judgment applies to State government medical colleges, marking a significant shift in India’s medical education policy.
- The Court held that domicile-based reservations violate Article 14 (Right to Equality) of the Constitution.
About the News
- This ruling dismantles a key mechanism used by States to secure a stable and locally suited medical workforce for their public health systems.
- While upholding meritocracy, the judgment overlooks the critical link between medical education policies and State-level public health planning.
- The decision centralises medical education governance, potentially disincentivising States from investing in government medical colleges.
- This shift could turn competitive federalism into a race to the bottom, where States lose motivation to invest in public medical education.
DOMICILE QUOTAS IN STATE HEALTH PLANNING
Role of Domicile Quotas:
- Domicile-based reservations in post-graduate medical courses play a crucial role in aligning State investments in medical education with local health-care workforce retention.
- States invest significant public funds to train medical students, with the expectation that these doctors will serve the local health system after graduation.
- Given chronic shortages of specialists, domicile quotas help ensure a predictable supply of doctors who are familiar with the State’s health-care needs and systems.
Misapplication of Legal Precedent:
- The Supreme Court’s reliance on Pradeep Jain vs Union of India (1984) to strike down domicile-based post-graduate reservations overlooks key differences between undergraduate (MBBS) and post-graduate (specialist) medical education.
- Post-graduate courses are the primary pipeline for replenishing specialist doctors, unlike MBBS courses that focus on foundational training.
- Removing domicile quotas disrupts this pipeline, forcing States to rely on unpredictable external recruitment to fill specialist positions.
Impact on State Investments in Medical Education:
- Without domicile quotas, States lose a critical policy tool for ensuring that public investment in medical colleges translates into a local specialist workforce.
- This weakens State incentives to fund medical education, which could lead to:
- Declining infrastructure in government medical colleges.
- Worsening regional disparities in health-care access.
Disparity with Central Institutions:
- Premier central institutions like AIIMS, PGIMER, and JIPMER enjoy greater autonomy in selecting candidates aligned with their institutional goals.
- State government medical colleges — which are even more critical for public health delivery at the grassroots level — are denied this same autonomy.
Constitutional and Public Health Link:
- Article 21 guarantees the right to life, which includes access to adequate health care — an area where States bear primary responsibility under their legislative competence over public health.
- Government medical colleges are not just educational institutions, but also serve as vital pillars of State health infrastructure.
- Viewing them only as academic centres ignores their larger role in public health delivery.
Need for State Autonomy:
A systems-based approach to public health planning highlights the need for State autonomy in:
- Admissions at undergraduate, post-graduate, and super-specialty levels.
- Policy formulation suited to local socio-economic and health conditions.
- Excessive centralisation — reinforced through court rulings — hinders State-specific health strategies, compromising both State-level public health governance and the right to health under Article 21.
Legislative and Judicial Responsibility:
- Both legislatures and the judiciary must recognise that State government medical colleges are integral components of public health infrastructure, not merely education hubs.
- Policies and judgments must reflect their dual role in both medical education and sustaining public health systems.
THE FALLACY OF ABSOLUTE MERITOCRACY
Rigid Merit Framework:
- The Supreme Court’s insistence on strict meritocracy overlooks the structural inequities present in India’s medical entrance system, particularly in NEET-PG.
- Analysis of NEET-PG results highlights flaws in the merit assessment process, including cases where candidates with negative marks qualify due to percentile-based cutoffs.
Example – NEET PG 2023:
- In 2023, the National Medical Commission (NMC), following Ministry of Health directives, reduced the qualifying percentile for NEET-PG and Super Speciality exams to zero to fill vacant seats.
- This demonstrates how merit standards are flexible in practice to accommodate administrative needs.
Inconsistent Approach to Equity:
- If regional and socio-economic disparities are recognised in undergraduate admissions, there is no strong justification for excluding such considerations in post-graduate admissions.
Narrow View of Merit:
- The Court’s approach reflects a narrow, decontextualised concept of merit, ignoring how social and economic contexts shape access to opportunities.
- Landmark judgments — including Jagdish Saran & Ors vs Union of India (1982), Pradeep Jain (1984), Neil Aurelio Nunes & Ors vs Union of India (2022), and Om Rathod vs The Director General of Health Services (2024) — have all recognised that:
- Administrative efficiency should be measured not just by abstract merit, but by outcomes that: Promote societal good; Redress structural inequalities.
Domicile Reservations and Social Merit:
- Domicile-based reservations prioritise candidates who are more likely to remain and serve in their home States, enhancing health-care access and reducing regional disparities.
- This aligns with a broader, more inclusive understanding of merit, which considers social outcomes rather than just exam performance.
- The Economic Survey 2024-25 also acknowledged the importance of local retention for strengthening regional health systems.
NEED FOR A RECONSIDERATION
Precedent and Changing Context:
- The Supreme Court’s ruling is based on precedents from Pradeep Jain and the Constitution Bench, but these precedents were framed in a very different health-care context.
- Today, retaining specialists within State health systems is more urgent than ever, particularly given:
- The COVID-19 pandemic.
- The rising burden of non-communicable diseases (NCDs).
Balanced Alternative Approach: Instead of outright elimination, a more balanced approach would:
- Retain domicile quotas, but link them to public service obligations.
- Example: Tamil Nadu’s medical education framework ties reservations to mandatory service in public health institutions, ensuring State investment directly benefits the local health-care system.
- Such innovative models deserve judicial and policy consideration, rather than blanket rejection.
Meritocracy Misapplication: The ruling reflects a well-intentioned but flawed application of meritocracy, which ignores the operational realities of:
- State public health governance.
- The State’s role in planning and managing health-care delivery.
Overreach into Policy Design: The judgment blurs the boundary between constitutional interpretation and detailed policy design, which should typically be the domain of legislatures and executive authorities.
- Risks of Over-Centralisation: By reinforcing centralised control over medical admissions, the ruling risks:
- Weakening State investment in medical education.
- Worsening regional health disparities.
- Eroding competitive federalism.
Call for Reconsideration:
- A reconsideration of the verdict is essential to ensure States retain autonomy to structure medical education policies aligned with their local health-care needs.
- The Court’s view that domicile quotas pose a national risk is misguided — instead, excessive centralisation poses a greater threat to federal health policy.
Judicial Doctrine and Health Policy: To build a robust, sustainable health-care system, judicial interpretation must evolve to:
- Acknowledge the complex interplay between medical education, federalism, and public health governance.
- Enable States to formulate context-specific policies without unwarranted interference.
Mains Question (250 words):
Critically examine the Supreme Court’s ruling striking down domicile-based reservations in post-graduate medical admissions. Discuss its implications on public health governance, competitive federalism, and State investment in medical education.