Holding

Residence‑based reservation in postgraduate medical courses is unconstitutional under Article 14, and only institutional preference reservations are permissible.

Summary

The case concerned the Government Medical College and Hospital, Chandigarh, which reserved 64 postgraduate (PG) medical seats under its State quota – 32 for candidates who had studied at the college (institutional preference) and 32 for candidates deemed "residents" of Chandigarh based on broad residence criteria. The Punjab and Haryana High Court struck down the residence‑based reservation as violative of Article 14, directing merit‑based admission, and the decision was appealed before the Supreme Court. The Supreme Court examined the constitutional validity of domicile/residence‑based reservation in PG medical courses, relying on the precedents of Jagadish Saran, Pradeep Jain and Saurabh Chaudri. It held that while institutional preference is a permissible classification, residence‑based reservation in PG courses infringes the equality guarantee under Article 14 and is therefore unconstitutional. Consequently, only the 32 institutional‑preference seats are valid; the other 32 must be filled on merit, but the students already admitted under the residence category are not disturbed. The appeal was dismissed and the High Court’s order upheld.

Issues considered

Whether providing domicile/residence‑based reservation in admission to PG Medical Courses within the State quota is constitutionally invalid and impermissible.
If such reservation were permissible, what would be the extent and manner of its provision.
If such reservation is impermissible, how should the State quota seats, other than institutional preference seats, be filled.

Legislation cited

Constitution of Indias. Art.14, s. Art.15, s. Art.16

Headnote

Issue for Consideration Whether providing domicile/residence-based reservation in admission to Postgraduate (PG) Medical Courses within the State Quota is constitutionally invalid and impermissible; Difference between domicile and residence discussed. Headnotes† Constitution of India, Reservation in PG Medical Course – Government Medical College and Hospital, Chandigarh reserved 64 PG medical seats in State Quota – 32 seats reserved for “residents” of State and 32 seats reserved for those who have done their MBBS from the same Medical College in

Subjects

PG Medical AdmissionsDomicile-based reservationState quota admissionsResidence-based reservationInstitutional preferenceArticle 14Equal opportunityMBBS vs. PG distinctionReservation in MBBSReservation in higher learning coursesMerit-based admissionsMeaning of domicile

Judgment

[2025] 1 S.C.R. 1209 : 2025 INSC 125

Dr. Tanvi Behl
v.
Shrey Goel & Ors.
(Civil Appeal No. 9289 of 2019)
29 January 2025
[Hrishikesh Roy, Sudhanshu Dhulia,* and S.V.N. Bhatti, JJ.]

Issue for Consideration
Whether providing domicile/residence-based reservation in
admission to Postgraduate (PG) Medical Courses within the State
Quota is constitutionally invalid and impermissible; Difference
between domicile and residence discussed.

Headnotes†
Constitution of India, Articles 14, 15, 16 – Reservation in PG
Medical Course – Government Medical College and Hospital,
Chandigarh reserved 64 PG medical seats in State Quota – 32
seats reserved for “residents” of State and 32 seats reserved
for those who have done their MBBS from the same Medical
College in Chandigarh, i.e., by institutional preference – Clause
of prospectus providing for such residence based reservation
challenged – High Court struck down such provision as being
unconstitutional for violating Art.14 and directed the Medical
College to fill seats according to merit – Appeal filed before
Supreme Court:
Held: The principle laid down in Pradeep Jain v. Union of India,
that residence-based reservation is impermissible in PG Medical
Courses, was followed by the Constitution Bench in Saurabh
Chaudri v. Union of India that governs the issue – Apart from
institutional preferences, which may be a reasonable classification
permissible under Art.14, as held in Saurabh Chaudri, reservation
on basis of residence in PG courses and other higher learning
courses violative of Art.14 – Reliance placed on Jagadish Saran
and Pradeep Jain to hold that residence-based reservation is
permissible for MBBS Courses to a reasonable degree – At PG
level merit cannot be compromised – MBBS is a basic medical
degree and insistence on highest talent may be relaxed – Role
of high grade skill may be more at higher levels of sophisticated
* Author
1210 [2025] 1 S.C.R.

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skills and strategic employment – Here equality, measured by
matching excellence, has more meaning and cannot be diluted
much without grave risk – Further held, although Art.15 does not
bar State from making ‘residence’ a requirement, for admission in
medical colleges or like matters and Art.16 speaks of residence in
context of employment under a State, both are different facets of
concept of equality embodied in Art.14 – Therefore, a legislation
has to still pass muster under Art.14 – Apart from reasonable
number of institution-based reservations, seats to be filled strictly
on merit in All-India examination – Thus, 32 seat validly filled on
basis of institutional preference – Other 32 seats wrongly filled
on basis of residence – Present Appellants granted admission
under the residence category and undergoing their course not to
be affected. [Paras 5, 8-17, 28-34]

Concept of “domicile” and residence/permanent residence –
Discussed:
Held: Legal concept of domicile different than that understood in
ordinary parlance – ‘Domicile’ is a legal concept for purposes of
determining what is the ‘personal law’ applicable to an individual –
The concept of domicile acquires importance only when within a
country there are different laws or more precisely different systems
of law operating which is not the case in India – Each citizen carries
one single domicile, ‘Domicile of India’, referred to as domicile in
the territory of India as under Art.5 – Regional or provincial domicile
is alien to Indian legal system – Reliance placed on Pradeep
Jain where the court held that the legal system which prevails
throughout the territory of India is one single indivisible system
with a single unified justice system and further condemned the
practice of wrongly using the nomenclature “domicile” in its popular
sense denoting residence – Reliance also placed on full bench of
Bombay High Court in The State v. Narayandas Mangilal Dayame
to hold merely because a State legislature makes laws on certain
subject matters, it will not mean that persons residing in that State
have a provincial domicile – Expression ‘domicile’ not relevant in
constructing competency of State Legislature. [Paras 18-25]

Reservation – In public employment on the basis of residence –
permissibility:
Held: The exception carved out under Clause 3 of Article 16, enables
only Parliament to make a law prescribing requirement of residence
[2025] 1 S.C.R. 1211

Dr. Tanvi Behl v. Shrey Goel & Ors.

for State employment – In situations which necessarily demand
prescription of residence within any State or UT as an essential
qualification it should be the Parliament (and not State legislatures)
which should be empowered to make a law for that purpose, so
that there is a uniformity throughout India on this. [Paras 25-27]

Case Law Cited
Jagadish Saran v. Union of India, 1980 INSC 12 : [1980] 2 SCR
831 : (1980) 2 SCC 768; Dr. Pradeep Jain v. Union of India [1984]
3 SCR 942 : (1984) 3 SCC 654; Saurabh Chaudri v. Union of India,
2003 INSC 597 : [2003] Supp. 5 SCR 152 : (2003) 11 SCC 146;
The State v. Narayandas Mangilal Dayame, AIR 1958 Bombay
68 (FB) – relied on.
Magan Mehrotra v. Union of India (2003) 11 SCC 186; Nikhil
Himthani v. State of Uttarakhand, 2013 INSC 517 : [2013] 14 SCR
23 : (2013) 10 SCC 237; Vishal Goyal v. State of Karnataka, 2014
INSC 322 : [2014] 5 SCR 606 : (2014) : 11 SCC 456; Neil Aurelio
Nunes v. Union of India, 2022 INSC 73 : [2022] 11 SCR 585 :
(2022) 4 SCC 1; D.P. Joshi v. State of Madhya Pradesh, 1955
INSC 3 : [1955] 1 SCR 1215 : AIR 1955 SC 334 – referred to.

Books and Periodicals Cited
Halsbury’s Laws of England (4th ed.), Vol-8, para 421 – referred to.

List of Acts
Constitution of India.

List of Keywords
PG Medical Admissions; Domicile-based reservation; State quota
admissions; Residence-based reservation; Institutional preference;
Article 14; Equal opportunity; MBBS vs. PG distinction; Reservation
in MBBS; Reservation in higher learning courses; Merit-based
admissions; Meaning of domicile.

Case Arising From
CIVIL APPELLATE/ORIGINAL JURISDICTION: Civil Appeal No.
9289 of 2019
From the Judgment and Order dated 23.04.2019 of the High Court
of Punjab & Haryana at Chandigarh in CWP No. 8234 of 2019
1212 [2025] 1 S.C.R.

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With
Civil Appeal Nos. 9290 and 9291 of 2019 and Writ Petition (C)
No. 1183 of 2020

Appearances for Parties
Advs. for the Appellant:
Ms. Swati Ghildiyal, Ms. Devyani Bhatt, Rohit Sharma, Jatin
Lalwani, Nikhil Purohit, Jay Rawat, Kumar Dushyant Singh, Rakesh
Dahiya, Aakash Dahiya, Aditya Dahiya, R N Mahlawat, Vikram
Gulia, Siddharth R. Gupta, Mrigank Prabhakar, Ms. Sunita Gupta,
Shantanu Sharma, Aman Agrawal, Ms. Sakshi Banga, Samar
Bansal, Amit Agrawal, Ms. Sana Jain, Arjun Chhibbar, K.K.L.
Gautam, Ms. Vaishali N., Madan S., R. Rani Chandra, Sanjeev
Malhotra
Advs. for the Respondents:
K.M. Nataraj, A.S.G., Ms. Garima Prasad, Sr. A.A.G., Prateek K.
Chadha, A.A.G., Nidhesh Gupta, Rahul Mehra, Saurabh Mishra,
Gaurav Sharma, Sr. Advs., Apoorv Kurup, Ms. Swarupama
Chaturvedi, Sandeep Kr. Mahapatra, Sughosh Subramanyam,
Amrish Kumar, Varun Chugh, Bhuvan Kapoor, Shreekant Neelappa
Terdal, Pukhrambam Ramesh Kumar, Karun Sharma, Ms. Anupama
Ngangom, Ms. Rajkumari Divyasana, Nishe Rajen Shonker, Mrs.
Anu K Joy, Alim Anvar, Ms. Namita Choudhary, Ashutosh Kumar
Sharma, Ms. Shefali Choudhary, Ms. K. Enatoli Sema, Ms. Limayinla
Jamir, Amit Kumar Singh, Ms. Chubalemla Chang, Prang Newmai,
Vishnu Shankar Jain, Ms. Marbiang Khongwir, Surjendu Sankar
Das, Samarpit Chauhan, Venkat Mani Tripathi, Avijit Mani Tripathi,
Ms. Japneet Kaur, Ms. Preeti Sehrawat, Azmat Hayat Amanullah,
Guntur Pramod Kumar, Ms. Prerna Singh, Samarth Luthra, Dhruv
Yadav, Abhimanyu Tewari, Ms. Eliza Bar, Aaditya Aniruddha Pande,
Siddharth Dharmadhikari, Bharat Bagla, Sourav Singh, Aditya
Krishna, Ms. Preet S. Phanse, Adarsh Dubey, Shaurya Sahay,
Aditiya Kumar, Nishe Rajen Shonker, Mrs. Anu K Joy, Alim Anvar,
Ms. Namita Choudhary, Ashutosh Kumar Sharma, Ms. Shefali
Choudhary, Surjendu Sankar Das, Samarpit Chauhan, Venkat
Mani Tripathi, Azmat Hayat Amanullah, Guntur Pramod Kumar,
Abhimanyu Tewari, Ms. Eliza Bar, Nishe Rajen Shonker, Mrs. Anu
K Joy, Alim Anvar, Ajith Anto Perumbully, Ms. Namita Choudhary,
Ashutosh Kumar Sharma, Ms. Shefali Choudhary, Surjendu Sankar
Das, Samarpit chauhan, Venkat Mani Tripathi, Avijit Mani Tripathi,
[2025] 1 S.C.R. 1213

Dr. Tanvi Behl v. Shrey Goel & Ors.

Ms. Japneet Kaur, Ms. Preeti Sehrawat, Guntur Pramod Kumar,
Vishnu Shankar Jain, Ms. Marbiang Khongwir, Azmat Hayat
Amanullah, Ms. Rebecca Mishra, Sagar Chauhan, Abhimanyu
Tewari, Ms. Eliza Bar, Sravan Kumar Karanam, Ms. Shireesh
Tyagi, Aniket Singh, Ms. Baani Khanna, Robin Singh, Rohit Kumar,
Govinda choudhary, Sarad Kumar Singhania, Divyansh Singh, V.
N. Raghupathy, Sreekar Aechuri, Shivendra Singh, Bikram Dwivedi,
Sagar Devgan, Gopal Sharan Pathak, Azmat Hayat Amanullah,
Ms. Baani Khanna, Robin Singh, Rohit Kumar, Govinda choudhary,
Anubhav Sharma, Gaurav Pathak Prakash, Nishant Kumar, Prateek
Bhatia, Dhawal Mohan, Paranjay Tripathi.

Judgment / Order of the Supreme Court

Judgment

Sudhanshu Dhulia, J.

1. The question before this Court is whether residence-based reservation
in Post Graduate (PG) Medical Courses by a State is constitutionally
valid? On this the precise questions formulated by the Division Bench
of this Court, which have now come up for determination before this
Court, are as follows:
"1. As to whether providing for domicile/residence-based
reservation in admission to “PG Medical Courses” within the
State Quota is constitutionally invalid and is impermissible?
2. (a) If answer to the first question is in the negative and
if domicile/residence-based reservation in admission to
“PG Medical Courses” is permissible, what should be the
extent and manner of providing such domicile/residence-
based reservation for admission to “PG Medical Courses”
within the State Quota seats?
2.(b) Again, if domicile/residence-based reservation
in admission to “PG Medical Courses” is permissible,
considering that all the admissions are to be based on
the merit and rank obtained in NEET, what should be
the modality of providing such domicile/residence-based
reservation in relation to the State/UT having only one
Medical College?
1214 [2025] 1 S.C.R.

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3. If answer to the first question is in the affirmative and
if domicile/residence-based reservation in admission to
“PG Medical Courses” is impermissible, as to how the
State Quota seats, other than the permissible institutional
preference seats, are to be filled up?
2. Before we come to answer these questions, we must state the facts
first in order to get a perspective of the case before us. The case is
from the Union Territory of Chandigarh which has just one Medical
College called ‘The Government Medical College and Hospital,
Chandigarh’ (hereinafter referred to as the ‘Medical College’). On
28.03.2019, the process of admissions to PG Medical Course in
the said Medical College had started. The Medical College had 64
PG Medical seats in its State Quota and the relevant clause of the
prospectus, which was challenged before the High Court of Punjab
and Haryana, distributed these seats as follows:
“2. State Quota: 64 seats. In compliance of the decision
of Hon’ble Punjab and Haryana High Court, distribution
of 50% State Quota seats are as below:

Category Total Reserved General
no. of (SC) 15%
seats
1. Institutional 32 5 27
Preference
Pool (IP)
2. UT, Chandigarh 32 5 27
Pool
Total 64 10 54

A. Institutional Preference Pool (IP): Candidates who
have passed their MBBS examination from Govt. Medical
College & Hospital Chandigarh
B. UT Chandigarh Pool: Candidate who fulfil eligibility
criteria as below: This category will include candidates with
background of Chandigarh. To be eligible for this category
candidate should fulfil any of the following criteria:
[2025] 1 S.C.R. 1215

Dr. Tanvi Behl v. Shrey Goel & Ors.

i. Studied for a period of 5 years in the Union Territory
of Chandigarh at any time prior to the last date of
the submission of the application.
ii. Candidates whose parents have resided in Union
Territory of Chandigarh for a period of at least 5 years
at any time prior to the last date of the submission
of the application either in pursuit of a profession or
holding a job.
iii. Children of persons who have held/hold immovable
property in Union Territory of Chandigarh for a period
of five years at any time prior to the last date of
the submission of 11 the application. The property
should be in the name of the parents or the candidate
himself/herself.
Important Note:
a) To be eligible for UT Chandigarh Pool under B(i), the
candidate must submit a certificate to the effect from
Principal of School/College located within the territory of
UT Chandigarh
b) To be eligible under B (ii), the candidate should submit
a certificate issued by the D.C of UT Chandigarh to the
effect that the candidate or his parents have been residing/
have resided in Chandigarh at least for 5 years
c) To be eligible under B (iii), the candidate must submit
a certificate issued by D.C-cum-Estate Officer/Tehsildar
stating that the candidate/parents of the candidate have
held/are holding immovable property in UT Chandigarh for
at least for 5 years prior to the submission of application.”
As it is clear, for the 64 seats falling under the State quota all are
reserved either for the ‘residents’ of Chandigarh or for those who
have done their MBBS from the same Medical College in Chandigarh.
3. Petitions were filed before the Punjab and Haryana High Court
challenging the above provision as it gave reservation on the basis
of residence, which resulted in all 64 seats being filled either by the
residents of Chandigarh or by students who had done their MBBS
from the same Medical College under institutional preference.
1216 [2025] 1 S.C.R.

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The petitioners therein had argued that the above provision was
in direct conflict with various decisions of the Supreme Court
including Jagadish Saran v. Union of India (1980) 2 SCC 768,
Dr. Pradeep Jain v. Union of India (1984) 3 SCC 654 and Saurabh
Chaudri v. Union of India (2003) 11 SCC 146. The High Court in
its well-considered decision, after taking note of the long line of
decisions of this Court, but primarily the three above-cited decisions,
came to the conclusion that the reservation made for the PG Medical
Course in the Medical College was on the basis of a long-discarded
principle of domicile or residence, was bad, and had allowed the
petitions cancelling the admission of such students.
4. The eligibilities stated in the prospectus for being a ‘resident’ of
Chandigarh are very wide and have no rationale to the objects
sought to be achieved. These even include a person who studied in
Chandigarh at any time for 5 years or the children of parents who had
property in Chandigarh for a period of 5 years at any point of time!
Be that as it may, the High Court held that there has been a violation
of Article 14 of the Constitution of India in granting such reservations.
Consequently, the clause 2B (i), (ii) and (iii) were declared invalid
and unconstitutional and all admissions which were made by placing
reliance on the above provision were held to be bad. It was directed
that the Medical College should now fill these seats according to
the merit position of candidates which they have obtained in their
NEET Examination.
The decision of the High Court was challenged before this Court and
the following interim order was passed by this Court on 09.05.2019:
“Permission to file special leave petitions is granted.
Application for exemption from filing certified copy of the
impugned order is allowed.
Permission to file additional documents is granted.
Issue notice, returnable on 2nd July, 2019.
Dasti, in addition, is permitted.
Counsel appearing for Medical Council of India waives
notice.
[2025] 1 S.C.R. 1217

Dr. Tanvi Behl v. Shrey Goel & Ors.

Liberty to the petitioner(s) to implead the students already
admitted to the post-graduate course for the academic
session 2019-2020.
There shall be ad-interim stay of the impugned order till
the next date of hearing.
It is, however, made clear that the admission process
already done on the basis of the stated provisions governing
domicile reservation will be subject to the outcome of
these petitions.”
5. Now, the Division Bench after framing of questions stated above,
referred the matter to this larger Bench. Let us straight away answer
the questions first: So far as question no. 1, which is whether
providing for domicile/residence-based reservation in admission to
“PG Medical Courses” within the State quota is constitutionally invalid
and impermissible is concerned, our answer is in the affirmative. Yes,
it is constitutionally invalid. In other words, providing for domicile or
residence-based reservation in PG Medical Courses is constitutionally
impermissible and cannot be done. Now, since our answer to the
first question is in the affirmative, we need not answer the next
two questions i.e., 2(a) and 2(b). We will answer the third question
towards the end of this judgment.
6. There are three judgments of this Court which have a significant
bearing on the question before us. The three judgments, in the order
of the year when they were delivered, are as follows:
(a) Jagadish Saran v. Union of India, (1980) 2 SCC 768
(b) Dr. Pradeep Jain v. Union of India, (1984) 3 SCC 654
(c) Saurabh Chaudri v. Union of India, (2003) 11 SCC 146
Whereas Jagadish Saran and Pradeep Jain are three judge Bench
decisions, Saurabh Chaudri is a Constitution Bench judgment of
five judges.
7. In Jagadish Saran, essentially the question before this Court was
whether institution-based reservation in PG Medical Courses is
constitutionally valid and permissible. The answer which was given
by the Court was that it is permissible to a reasonable extent as it
only creates reasonable classification which has a nexus with the
1218 [2025] 1 S.C.R.

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object sought to be achieved and hence it is not violative of Article
14 of the Constitution of India. Although the question in Jagadish
Saran was not directly related to residence-based or domicile-based
reservation, yet while answering the main question Justice Krishna
Iyer in his inimitable manner did touch upon various other aspects,
including residence and its importance, and most of all the importance
of having merit-based reservation in Post Graduate Medical studies.
8. In Pradeep Jain, the question before this Court was directly relating
to residence-based reservation in PG Medical courses and whether
that is permissible in law, and the answer given by this Court was
that though institution-based reservation is permissible, as held in
Jagadish Saran, but reservation made in PG Medical seats on the
basis of residence is impermissible and would be violative of Article
14 of the Constitution of India. This line of reasoning and ultimately,
the law laid down in Pradeep Jain was followed by the Constitution
Bench of Saurabh Chaudri.
9. Now, once the Five Judge Constitution Bench (Saurabh Chaudri),
has answered the question in affirmative, which is that residence-
based or domicile-based reservation in PG Medical courses is
impermissible and constitutionally invalid, we did wonder initially why
these questions were framed at all in this case and referred to us.
One possible reason why this was done perhaps was that Saurabh
Chaudri has to be deciphered as it was dealing with complex issues
and while relying heavily on Pradeep Jain, which in turn, relies on
Jagadish Saran, it becomes difficult to demarcate where Saurabh
Chaudri ends and Pradeep Jain or Jagadish Saran begins. But
then a closer look at Saurabh Chaudri, leaves one with no doubt
that it has followed Pradeep Jain entirely and therefore what has
been held in Saurabh Chaudri is the same what was earlier held
in Pradeep Jain, which is that residence-based reservation is not
permissible in PG Medical Courses.
10. We first have to see the question before the Court in Saurabh
Chaudri and who were the petitioners before the Court? In Saurabh
Chaudri, the petitioners (52 in number), were residents of Delhi,
who had joined various medical colleges outside Delhi for their
MBBS under an All-India quota, and after completing their MBBS
from outside now wanted to join medical colleges in Delhi for their
PG Medical Course. Their claim for admission was based on the
[2025] 1 S.C.R. 1219

Dr. Tanvi Behl v. Shrey Goel & Ors.

fact that they are ‘residents of Delhi’ and therefore they should be
granted admission under the residential quota which was otherwise
reserved only for students who had done their MBBS from Delhi.
This Court, however, declined to grant them relief and their petition
was dismissed for the reason that residence-based reservation is
impermissible. The Court while dismissing their claim in Saurabh
Chaudri followed the reasoning given in a recently decided case of
Supreme Court in Magan Mehrotra & Ors. v. Union of India & Ors.
(2003) 11 SCC 186, which had relied totally on Pradeep Jain and
held that apart from institutional preferences, no other preferences
including reservation on the basis of residence is envisaged in the
Constitution.
11. Interestingly the appellants before this Court too rely on Saurabh
Chaudri and would argue that in Saurabh Chaudri this Court had
held that residence-based reservation is not barred under Article 15
of the Constitution. It is true that Saurabh Chaudri does say that,
which is indeed the correct position in law. But this would not be a
complete reading of Saurabh Chaudri!
12. The question in Saurabh Chaudri was the validity of institutional
preference/reservation as well as reservation based on residence.
The precise questions before the Court, in its own words are as
follows: (SCC p. 155, para 10)
“10. The question which was initially raised in the writ
petition was as to whether reservation made by way of
institutional preference is ultra vires Articles 14 and 15 of
the Constitution of India; but during hearing a larger issue
viz. as to whether any reservation, be it on residence or
institutional preference, is constitutionally permissible, was
raised at the Bar.”
It answered in the affirmative for institutional preference and held
that to be a reasonable classification permissible under Article 14
of the Constitution of India.
13. While doing so Saurabh Chaudri relies heavily on both Pradeep
Jain and Jagadish Saran. Passages after passages have been
quoted from both Jagadish Saran and Pradeep Jain with approval.
At this stage we must also remember that to a reasonable degree
residence-based reservation in a State is permissible for MBBS
Courses (Pradeep Jain), but the same reservation for PG Courses
1220 [2025] 1 S.C.R.

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is not permissible by a long line of decisions of this Court, including
Pradeep Jain.
14. The difference in the logic in making reservations on the basis of
residence in UG level or MBBS level, and PG level (i.e. MD or
MS) was explained in Jagadish Saran as well as Pradeep Jain. It
was held that at PG level merit cannot be compromised, although
residence- based reservation can be permissible to a certain degree
in UG or MBBS course. While coming down heavily on residence-
based reservation in PG medical courses, it referred to the opinion
of the Medical Education Review Committee [relied upon in Saurabh
Chaudri (SCC p. 168, para 48)], which are as follows :- (SCC p.
690, para 22)
“22. …‘all admissions to the postgraduate courses in
any institution should be open to candidates on an all-
India basis and there should be no restriction regarding
domicile in the State/Union Territory in which the institution
is located’.”
15. Why residence-based reservation is impermissible is for the reason
that such reservation runs counter to the idea of citizenship and
equality under the Constitution. It was said as under in Pradeep
Jain :- (SCC p. 672, para 10)
“10. … Now, the primary imperative of Article 14 is equal
opportunity for all across the nation for education and
advancement and, as pointed out by Krishna Iyer, J. in
Jagadish Saran (Dr) v. Union of India [(1980) 2 SCC 768
: AIR 1980 SC 820] ‘this has burning relevance to our
times when the country is gradually being “broken up
into fragments by narrow domestic walls” by surrender to
narrow parochial loyalties’. What is fundamental, as an
enduring value of our polity, is guarantee to each of equal
opportunity to unfold the full potential of his personality.
Anyone anywhere, humble or high, agrestic or urban,
man or woman, whatever be his language or religion,
place of birth or residence, is entitled to be afforded
equal chance for admission to any secular educational
course for cultural growth, training facility, speciality or
employment. It would run counter to the basic principle
of equality before the law and equal protection of the
[2025] 1 S.C.R. 1221

Dr. Tanvi Behl v. Shrey Goel & Ors.

law if a citizen by reason of his residence in State A,
which ordinarily in the commonality of cases, would be
the result of his birth in a place situate within that State,
should have opportunity for education or advancement
which is denied to another citizen because he happens
to be resident in State B. It is axiomatic that talent is not
the monopoly of the residents of any particular State;
it is more or less evenly distributed and given proper
opportunity and environment, everyone has a prospect
of rising to the peak. What is necessary is equality of
opportunity and that cannot be made dependent upon
where a citizen resides.”
The above passage from Pradeep Jain was relied upon in Saurabh
Chaudri (SCC p. 166, para 46), while coming to the same conclusion.
16. There is no doubt that Saurabh Chaudri though holds institutional
preference or reservations to a reasonable extent permissible under
the Constitution in PG courses, yet holds reservation in PG Medical
Courses and other higher learning courses, on the basis of ‘residence’
in the State as violative of Article 14 of the Constitution of India.
17. Article 14 of the Constitution of India speaks of Right to equality and
declares that “the State shall not deny to any person equality before
the law or the equal protection of law within the territory of India”.
Other Articles such as Article 15, 16, 17 and 18 are only different
facets of Right to equality.
18. Article 15 as it existed in the original Constitution declares that the
State shall not discriminate on the grounds of religion, race, caste,
sex or place of birth, though clause 3 is in the nature of a proviso
leaving it open for the State to make any special provision for
women and children. Later, clauses 4, 5 and 6 were added by way
of amendments to Article 15, creating similar enabling provisions for
other classes of citizens such as socially and educationally backward
classes, Scheduled Castes, Scheduled Tribes and Economically
Weaker Section of citizens in educational institutions. We are primarily
concerned here with Articles 14 and 15 of the Constitution of India and
we have to determine whether these provisions prohibit residence-
based reservations in PG Medical courses. But before we do that,
we must settle one question, which is the concept of ‘domicile’, and
domicile being equated to residence or permanent residence, by
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the State machinery or by educational institutions in a loose/casual
manner. These concepts needs to be clarified.
19. Domicile in normal parlance denotes ‘the place of living’ or permanent
residence. The legal concept is, however, different. Domicile as stated
in Halsbury’s Laws of England1 is “the legal system which invokes
that system as his personal law”. The purpose for which domicile is
used by Governments is like a substitute for ‘permanent residence’
or a ‘permanent home’. Yet ‘domicile’ is primarily a legal concept for
the purposes of determining what is the ‘personal law’ applicable
to an individual. Therefore, even if an individual has no permanent
residence or permanent home, he is still invested with a ‘domicile’
albeit by law or implication of law. Consequently, the concept of
domicile acquires importance only when within a country there are
different laws or more precisely different systems of law operating.
But this is not the case in India. Each citizen of this country carries
with him or her, one single domicile which is the ‘Domicile of India’.
The concept of regional or provincial domicile is alien to the Indian
legal system. The seminal decision on this subject is Pradeep Jain.
The aspect of domicile is fully explained and elaborated, and needs
to be referred to here. Firstly, paragraph 8 of the said judgment would
be relevant, which reads as follows: (SCC p.668 para 8)
“8. Now it is clear on a reading of the Constitution that it
recognises only one domicile, namely, domicile in India.
Article 5 of the Constitution is clear and explicit on this
point and it refers only to one domicile, namely, “domicile
in the territory of India.” Moreover, it must be remembered
that India is not a federal State in the traditional sense of
that term. It is not a compact of sovereign States which
have come together to form a federation by ceding a part
of their sovereignty to the federal State. It has undoubtedly
certain federal features but it is still not a federal State
and it has only one citizenship, namely, the citizenship of
India. It has also one single unified legal system which
extends througout the country. It is not possible to say
that a distinct and separate system of law prevails in
each State forming part of the Union of India. The legal

1 Halsbury’s Laws of England (4th ed.), Vol-8, para 421.
[2025] 1 S.C.R. 1223

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system which prevails throughout the territory of India is
one single indivisible system with a single unified justicing
system having the Supreme Court of India at the apex
of the hierarchy, which lays down the law for the entire
country. It is true that with respect to subjects set out in List
II of the Seventh Schedule to the Constitution, the States
have the power to make laws and subject to the overriding
power of Parliament, the State can also make laws with
respect to subjects enumerated in List III of the Seventh
Schedule to the Constitution, but the legal system under
the rubric of which such laws are made by the States is a
single legal system which may truly be described as the
Indian legal system. It would be absurd to suggest that
the legal system varies from State to State or that the
legal system of a State is different from the legal system
of the Union of India, merely because with respect to the
subjects within their legislative competence, the State
have power to make laws. The concept of ‘domicile’ has
no relevance to the applicability of municipal laws, whether
made by the Union of India or by the States. It would not,
therefore, in our opinion be right to say that a citizen of
India is domiciled in one State or another forming part of
the Union of India. The domicile which he has is only one
domicile, namely, domicile in the territory of India. When a
person who is permanently resident in one State goes to
another State with intention to reside there permanently
or indefinitely, his domicile does not undergo any change :
he does not acquire a new domicile of choice. His domicile
remains the same, namely, Indian domicile. We think it
highly detrimental to the concept of unity or integrity of
India to think in terms of State domicile...”
20. This Court also took note of the common misconception with the
State Governments on domicile and had observed that it is not
uncommon for the State Governments to use the term ‘domicile’
when what they actually intend to mean is ‘permanent residence’,
or even ‘residence’.
21. In Pradeep Jain, the argument that domiciliary requirement for
admission to medical colleges and other colleges situated within the
State territory is used not in its legal sense but in a popular sense
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denoting residence or an intention to reside permanently, was also
discussed, and this practice of wrongly using the nomenclature
‘domicile’ was condemned. This is what was said: (SCC p.669 para 8)
“8…We think it is dangerous to use a legal concept for
conveying a sense different from that which is ordinarily
associated with it as a result of legal usage over the years.
When we use a word which has come to represent a
concept or idea for conveying a different concept or idea,
it is easy for the mind to slide into an assumption that
the verbal identity is accompanied in all its sequences by
identity or meaning. The concept of domicile if used for a
purpose other than its legitimate purpose may give rise to
lethal radiations which may in the long run tend to break up
the unity and integrity of the country. We would, therefore,
strongly urge upon the State Governments to exercise
this wrong use of the expression ‘domicile’ from the rules
regulating admissions to their educational institutions and
particularly medical colleges and to desist from introducing
and maintaining domiciliary requirement as a condition of
eligibility for such admissions.”
The judgment at another place speaks as under: (SCC pp.664-665
para 3, 4)
“3… Now if India is one nation and there is only one
citizenship, namely, citizenship of India, and every citizen
has a right to move freely throughout the territory of India
and to reside and settle in any part of India, irrespective of
the place where he is born or the language which he speaks
or the religion which he professes and he is guaranteed
freedom of trade, commerce and intercourse throughout
the territory of India and equal protection of the law with
other citizens in every part of the territory of India, it is
difficult to see how a citizen having his permanent home
in Tamilnadu or speaking Tamil language can be regarded
as an outsider in Uttar Pradesh or a citizen having his
permanent home in Maharashtra or speaking Marathi
language be regarded as an outsider in Karnataka. He
must be held entitled to the same rights as a citizen having
his permanent home in Uttar Pradesh or Karnataka as the
[2025] 1 S.C.R. 1225

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case may be. To regard him as an outsider would be to
deny him his constitutional rights and to derecognize the
essential unity and integrity of the country by treating it as
if it were a mere conglomeration of independent states.
4. But, unfortunately, we find that in the last few years,
owing to the emergence of narrow parochial loyalties
fostered by interested parties with a view to gaining
advantage for themselves, a serious threat has developed
to the unity and integrity of the nation and the very
concept of India as a nation is in peril. The treat is
obtrusive at some places while at others it is still silent
and is masquerading under the guise of apparently
innocuous and rather attractive clap-trap. The reason
is that when the Constitution came into operation, we
took the spirit of nationhood for granted and paid little
attention to nourish it, unmindful of the fact that it was a
hardwon concept. We allowed ‘sons of the soil’ demands
to develop claiming special treatment on the basis of
residence in the concerned State, because recognizing
and conceding such demands had a populist appeal.
The result is that ‘sons of the soil’ claims, though not
altogether illegitimate if confined within reasonable
bounds, are breaking as under the unity and integrityof
the nation by fostering and strengthening narrow parochial
loyalties based on language and residence within a State.
Today unfortunately, a citizen who has his permanent
residence in a State entertains the feeling that he must
have a preferential claim to be appointed to an office
or post in the State or to be admitted to an educational
institution within the State vis-à-vis a citizen who has
his permanent residence in another State, because the
latter is an outsider and must yield place to a citizen
who is a permanent resident of the State, irrespective of
merit. This, in our opinion, is a dangerous feeling which,
if allowed to grow, indiscriminately, might one day break
up the country into fragments...”
22. Much before Pradeep Jain, a full bench of the Bombay High Court
had an occasion to examine the concept of domicile. In this judgment,
delivered by Chief Justice M.C. Chagla in The State v. Narayandas
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Mangilal Dayame reported in AIR 1958 Bombay 68 (FB), the Full
Bench stated as under:
“7. Now in our opinion, it is a total misapprehension of
the position in law in our country to talk of a person being
domiciled in a province or in a State. A person can only
be domiciled in India as a whole. That is the only country
that can be considered in the context of the expression
“domicile” and the only system of law by which a person
is governed in India is the system of law which prevails
in the whole country and not any system of law which
prevails in any province or State. It is hardly necessary
to emphasize that unlike the United States of America,
India has a single citizenship. It has a single system of
Courts of law and a single judiciary and we do not have
in India the problem of duality that often arises in the
American Law, the problem which arises because of a
federal citizenship and a State citizenship. Therefore, in
India we have one citizenship, the citizenship of India. We
have one domicile—the domicile in India and we have
one legal system - the system that prevails in the whole
country. The most that one can say about a person in a
State is that he is permanently resident in a particular
State. But as Halsbury points out, to which we have just
made reference, the mere fact that a man’s home maybe
fixed at a particular spot within the country does not make
him domiciled in that spot but makes him domiciled in the
whole country, and therefore, whether a man permanently
resides in Bombay or Madras or Bengal or anywhere does
not make him domiciled in Bombay, Madreas or Bengal
but makes him domiciled in India; Bombay, Madras and
Bengal being particular spots in India as a country.”
23. In the same judgment it was also explained that merely because a
State legislature makes laws on certain subject matters, it will not
ipso facto mean that persons residing in that State have a provincial
domicile:
“8…The competence of the Legislature is not limited
to passing of laws which would only apply to persons
domiciled within the State. Any law passed by a State
[2025] 1 S.C.R. 1227

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Legislature can be applied to any person within the State,
and therefore the expression ‘domicile’ has no relevancy
whatever in constructing the competency of the State
Legislature. If the State Legislature is legislating on a topic
within its competence, that law can be made applicable to
anyone in the State of Bombay whether he is a resident or
not or even if he is a foreigner passing through the State
of Bombay. Therefore, it is fallacious to suggest that the
doctrine of domicile is introduced in our law by person of
the fact that the State or the Provincial Legislature has
been given the power to legislate with regard to certain
subject-matters within its territorial ambit. It, therefore,
seems to us that the expression ‘domicile’ used in any
State or Provincial law is a misnomer and it does not carry
with the implications which that expression has when used
in the context of international law…”
24. In short, the very concept of a provincial or state domicile in India
is a misconception. There is only one domicile in India, which we
refer to as domicile in the territory of India as given under Article 52.
All Indians have only one domicile, which is the Domicile of India.
25. Permanent residence or residence have a meaning which is different
from that of ‘domicile’. Article 15 speaks of ‘place of birth’, whereas
Article 16 states that no citizen shall be discriminated, inter alia, on
the ground of ‘residence’. State cannot grant reservation in public
employment on the basis of residence in that State. The exception
carved out under Clause 3 of Article 16, enables only the Parliament
to make a law prescribing a requirement of residence for State
employment. And there is a reason behind it.
26. During the Constituent Assembly debates a question arose whether
residence in a State should be a criterion for appointment in
government service of that State. The overwhelming opinion was
that it should not. Since there is one citizenship, a citizen should
have a right to reside anywhere in the country and similarly seek

2 Citizenship at the commencement of the Constitution: At the commencement of this Constitution,
every person who has his domicile in the territory of India and—
(a) who was born in the territory of India; or
(b) either of whose parents was born in the territory of India; or
(c) who has been ordinarily resident in the territory of India for not less than five years immediately
preceding such commencement, shall be a citizen of India.
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a job anywhere in the country, this was the dominant feeling. For
those who had doubts on this, Dr. Ambedkar had a solution, which
he explained as follows:
“It is the feeling of many persons in this House that, since
we have established a common citizenship throughout
India, irrespective of the local jurisdiction of the provinces
and the Indian States, it is only a concomitant thing that
residence should not be required for holding a particular
post in a particular State because, in so far as you make
residence a qualification, you are really subtracting
from the value of a common citizenship which we have
established by this Constitution or which we propose to
establish by this Constitution. Therefore in my judgment,
the argument that residence should not be a qualification
to hold appointments under the State is a perfectly valid
and a perfectly sound argument. At the same time, it must
be realised that you cannot allow people who are flying
from one province to another, from one State to another,
as mere birds of passage without any roots, without any
connection with that particular province, just to come, apply
for posts and, so to say, take the plums and walk away.
Therefore, some limitation is necessary. It was found, when
this matter was investigated, that already today in very
many provinces rules have been framed by the provincial
governments prescribing a certain period of residence
as a qualification for a post in that particular province.
Therefore the proposal in the amendment that, although
as a general rule residence should not be a qualification,
yet some exception might be made, is not quite out of
the ordinary. We are merely following the practice which
has been already established in the various provinces.
However, what we found was that while different provinces
were laying down a certain period as a qualifying period
for posts, the periods varied considerably. Some provinces
said that a person must be actually domiciled. What that
means, one does not know. Others have fixed ten years,
some seven years and so on. It was therefore felt that,
while it might be desirable to fix a period as a qualifying
test, that qualifying test should be uniform throughout India.
[2025] 1 S.C.R. 1229

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Consequently, if that object is to be achieved, viz., that the
qualifying residential period should be uniform, that object
can be achieved only by giving the power to Parliament
and not giving it to the local units, whether provinces or
States. That is the underlying purpose of this amendment
putting down residence as a qualification.”3
27. It was ultimately decided that residence cannot be a ground for
discrimination in matters relating to employment, but in situations
which necessarily demand prescription of residence within any State
or UT as an essential qualification, it should be the Parliament (and
not State legislatures) which should be empowered to make a law for
that purpose, so that there is a uniformity throughout India on this.
28. But all this was again on Article 16, which deals with the matters of
service and employment under a State. As compared to Article 16,
Article 15 is a general provision having a wider application (including
the issue of reservation to college admissions), and it does not
contain ‘residence’ as one of the prohibitory grounds, and apparently
one can say that Article 15 does not bar the State from making
‘residence’ as a requirement, for admission in medical colleges or
like matters. We must, however, remember that both Article 15 and
Article 16 are different facets of the concept of equality, embodied
in Article 14 and therefore, a legislation can still be struck down if
it creates an unjustifiable classification, such as between residents
of a State and all others. Article 15 does not speak of ‘residence’, it
only speaks of ‘place of birth’ and the two concepts are different (D.P.
Joshi v. State of Madhya Pradesh AIR 1955 SC 334). Article 16
does speak of residence but then it is in the context of employment
under a State, with which we are presently not concerned. Yet the
residence requirement has still to pass muster Article 14 of the
Constitution of India.
29. It is now necessary to refer to the detail reasoning given in Pradeep
Jain as to why residence-based reservation in PG Medical courses is
violative of Article 14 of the Constitution of India, though to maintain
a balance and for consideration of local needs such reservation may
be permissible in MBBS courses. The reasoning given was that it is
the State which spends money on creating the infrastructures and

3 Constituent Assembly Debates, Vol-VII, pgs.700-701.
1230 [2025] 1 S.C.R.

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bears the expenses for running a medical college, and therefore some
reservation at the basic level of a medical course i.e. MBBS can be
permissible for the residents of that State. The classification between
residents and others here can be justified as the classification seeks to
maintain a balance as it considers local needs, backwardness of the
area, the expense borne by the State in creating the infrastructure, etc.
The reason as to why residence-based reservation is permissible for
MBBS Course and not for higher courses i.e. starting from PG Course
in medicine, is given in Jagadish Saran as well as Pradeep Jain.
It is extremely well articulated by Justice Krishna Iyer in Jagadish
Saran. Therefore the reasoning given for this classification must be
reproduced in order to get a better understanding as to why it was
done. Firstly, the fundamental reason as to why reservation must
be given in educational institution was stated as follows :- (SCC p.
785 para 40)
“40. … The class which enjoys reservation must be
educationally handicapped. The reservation must be geared
to getting over the handicap. The rationale of reservation
must be in the case of medical students, removal of regional
or class inadequacy or like disadvantage. The quantum of
reservation should not be excessive or societally injurious,
measured by the overall competency of the end-product
viz. degree-holders. A host of variables influence the
quantification of the reservation. But one factor deserves
great emphasis. The higher the level of the speciality the
lesser the role of reservation. Such being the pragmatics
and dynamics of social justice and equal rights, let us
apply the tests to the case on hand.”
For this reason, reservations at MBBS level was justified :- (SCC
p. 785 para 42)
“42. MBBS is a basic medical degree and insistence
on the highest talent may be relaxed by promotion of
backward groups, institution-wise chosen, without injury
to public welfare. It produces equal opportunity on a
broader basis and gives hope to neglected geographical
or human areas of getting a chance to rise. Moreover, the
better chances of candidates from institutions in neglected
[2025] 1 S.C.R. 1231

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regions setting down for practice in these very regions
also warrants institutional preference because that policy
helps the supply of medical services to these backward
areas. After all, it is quite on the cards that some out of
these candidates with lesser marks may prove their real
mettle and blossom into great doctors. Again, merit is not
measured by marks alone but by human sympathies. The
heart is as much a factor as the head in assessing the
social value of a member of the profession. Dr Samuel
Johnson put this thought with telling effect when he said:
“Want of tenderness is want of parts, and is
no less a proof of stupidity than of depravity.”
We have no doubt that where the human region from
which the alumni of an institution are largely drawn is
backward, either from the angle of opportunities for
technical education or availability of medical services for
the people, the provision of a high ratio of reservation
hardly militates against the equality mandate viewed in
the perspective of social justice.”
But then the same principle will not be applicable when we talk of
higher level of education like PG Medical Courses and the reason
given in Jagadish Saran is in para 23 :- (SCC pp. 778-79, para 23)
“The basic medical needs of a region or the preferential
push justified for a handicapped group cannot prevail
in the same measure at the highest scales of speciality
where the best skill or talent, must be handpicked by
selecting according to capability. At the level of PhD,
MD, or levels of higher proficiency, where international
measure of talent is made, where losing one great
scientist or technologist in-the-making is a national loss,
the considerations we have expanded upon as important
lose their potency. Here equality, measured by matching
excellence, has more meaning and cannot be diluted
much without grave risk. The Indian Medical Council has
rightly emphasised that playing with merit for pampering
local feeling will boomerang. Midgetry, where summitry
is the desideratum, is a dangerous art. We may here
extract the Indian Medical Council’s recommendation,
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which may not be the last word in social wisdom but is
worthy of consideration:
Students for post-graduate training should be
selected strictly on merit judged on the basis of
academic record in the under-graduate course.
All selection for post-graduate studies should
be conducted by the universities.”
30. It was reiterated further : (SCC p. 785 para 39)
“39. If equality of opportunity for every person in the
country is the constitutional guarantee, a candidate who
gets more marks than another is entitled to preference for
admission. Merit must be the test when choosing the best,
according to this rule of equal chance for equal marks.
This proposition has greater importance when we reach
the higher levels of education like post-graduate courses.
After all, top technological expertise in any vital field like
medicine is a nation’s human asset without which its
advance and development will be stunted. The role of high
grade skill or special talent may be less at the lesser levels
of education, jobs and disciplines of social inconsequence,
but more at the higher levels of sophisticated skills and
strategic employment. To devalue merit at the summit is
to temporise with the country’s development in the vital
areas of professional expertise. In science and technology
and other specialised fields of developmental significance,
to relax lazily or easily in regard to exacting standards of
performance may be running a grave national risk because
in advanced medicine and other critical departments of
higher knowledge, crucial to material progress, the people
of India should not be denied the best the nation’s talent
lying latent can produce. If the best potential in these
fields is cold-shouldered for populist considerations garbed
as reservations, the victims, in the long run, may be the
people themselves. Of course, this unrelenting strictness
in selecting the best may not be so imperative at other
levels where a broad measure of efficiency may be good
enough and what is needed is merely to weed out the
worthless.”
[2025] 1 S.C.R. 1233

Dr. Tanvi Behl v. Shrey Goel & Ors.

These findings in Jagadish Saran have been approved and followed
in Saurabh Chaudri (SCC p.168 para 48).
31. We are all domiciled in the territory of India. We are all residents of
India. Our common bond as citizens and residents of one country
gives us the right not only to choose our residence anywhere in
India, but also gives us the right to carry on trade & business or
a profession anywhere in India. It also gives us the right to seek
admission in educational institutions across India. The benefit of
‘reservation’ in educational institutions including medical colleges
to those who reside in a particular State can be given to a certain
degree only in MBBS courses, for which we have assigned reasons
in the preceding paragraphs. But considering the importance of
specialists doctors’ in PG Medical Course, reservation at the higher
level on the basis of ‘residence’ would be violative of Article 14 of the
Constitution of India. This has been explained with pronounced clarity
both in Jagadish Saran and Pradeep Jain. If such a reservation
is permitted then it would be an invasion on the fundamental rights
of several students, who are being treated unequally simply for the
reasons that they belong to a different State in the Union! This would
be a violation of the equality clause in Article 14 of the Constitution
and would amount to a denial of equality before the law.
32. The law laid down in Jagadish Saran and Pradeep Jain has
been followed by this Court in a number of decisions including the
Constitution Bench decision in Saurabh Chaudri. We may also refer
here judgments such as Magan Mehrotra and Ors. v. Union of India
(UOI) and Ors. (2003) 11 SCC 186, Nikhil Himthani vs. State of
Uttarakhand and Others (2013) 10 SCC 237, Vishal Goyal and
Others v. State of Karnataka and Others (2014) 11 SCC 456 and
Neil Aurelio Nunes (OBC Reservation) and Others v. Union of
India and Others (2022) 4 SCC 1, which have all followed Pradeep
Jain. Thus, residence-based reservations are not permissible in PG
medical courses.
33. Having made the above determination that residence-based
reservation is impermissible in PG Medical courses, the State
quota seats, apart from a reasonable number of institution-based
reservations, have to be filled strictly on the basis of merit in the
All-India examination. Thus, out of 64 seats which were to be filled
by the State in its quota 32 could have been filled on the basis of
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institutional preference, and these are valid. But the other 32 seats
earmarked as U.T. Chandigarh pool were wrongly filled on the basis
of residence, and we uphold the findings of the High Court on this
crucial aspect.
34. We make it clear though that our declaration of impermissibility of
residence-based reservation in PG Medical courses will not affect
such reservations already granted, and students are undergoing
PG courses or have already passed out in the present case, from
Government Medical College, Chandigarh. We do this simply
because now there is an equity in favour of such students who
must have already completed the course. Logically, therefore, the
present appellants who were granted admission under the residence
category and were undergoing their course, & also by virtue of the
interim order of this Court dated 09.05.2019, will not be affected by
our judgment.
35. The present appeal stands disposed of in the above terms. The
connected appeals and writ petition stand decided in the light of our
order in the present case.
36. Pending application(s), if any, stand(s) disposed of.

Result of the case: Appeal disposed of.

†
Headnotes prepared by: Aandrita Deb, Hony. Associate Editor
(Verified by: Abhinav Mukerji, Sr. Adv.)