TANVI BEHL vs SHREY GOEL

TANVI BEHL vs SHREY GOEL

Case nameTANVI BEHL vs SHREY GOEL
Case numberC.A. No. 9289/2019
Court typeSupreme Court of India
Judgment date29 January 2025
BenchHrishikesh Roy, Sudhanshu Dhulia and S.V.N. Bhatti JJ.

Case Background

Parties and procedural roles: Tanvi Behl and connected medical aspirants were appellants contesting domicile or residence-based eligibility for postgraduate medical admission. Shrey Goel and other candidates or admission authorities were respondents defending the applicable quota; States and medical colleges were affected by the constitutional rule. Supreme Court proceedings generally describe the sides as petitioner/appellant and respondent, or accused and prosecution, rather than plaintiff and defendant. In a suo motu case or constitutional reference, the Court or President initiates the proceeding and governments, authorities and affected stakeholders assist or respond.

Detailed story and problem statement: Dr Tanvi Behl, Shrey Goel and connected medical candidates disputed Chandigarh’s reservation of postgraduate medical seats for residents/domiciles. UT authorities defended local access and workforce needs. The controversy became legally significant because the challenged action affected liberty, equality, institutional fairness, democratic accountability, property, family relations, professional rights or another protected interest. The side seeking relief said that the governing legal safeguards had not been honoured; the opposing side relied on its statutory power, the record and the need for workable administration or enforcement.

Procedural development: Conflicting admission challenges were referred to three judges; the constitutional rule was settled on 29 January 2025. The matter reached the Supreme Court as C.A. No. 9289/2019. Against this factual and procedural setting, the Court had to resolve: Can States or Union Territories reserve PG medical seats on residence/domicile grounds?

Key Arguments

Challengers said India recognises only one domicile and PG specialty seats must be merit-based, though institutional preference may be allowed. Authorities invoked local investment and State quota.

Arguments supporting relief: The petitioner, appellant, accused or assisting party seeking intervention relied on Single Indian domicile; merit; residence reservation, the guarantees in Articles 5, 14, 15 and 16, and the language and purpose of Medical Council/NMC postgraduate admission regulations and Chandigarh prospectus. That side argued that legal power is limited by fairness, relevant evidence, reasoned decision-making and proportionality. It asked the Court to examine the actual burden imposed and to grant effective relief rather than leave the alleged violation without a remedy.

Arguments opposing relief: The respondent government, regulator, prosecution, employer or private party relied on statutory competence, institutional autonomy, contractual or procedural rules, public interest, finality, administrative feasibility or the strength of the factual record, according to the nature of TANVI BEHL vs SHREY GOEL. It urged restraint and argued that the challenged outcome fell within lawful discretion or that the requirements for extraordinary Supreme Court intervention were not met.

Judicial comparison: The bench tested these positions against precedent, statutory ingredients, the evidentiary and procedural record, and consequences for similarly situated people or institutions. The controlling questions were: Can States or Union Territories reserve PG medical seats on residence/domicile grounds?

Case timeline

Conflicting admission challenges were referred to three judges; the constitutional rule was settled on 29 January 2025.

Questions of Law

Can States or Union Territories reserve PG medical seats on residence/domicile grounds?

Judgment

The Court held residence-based reservation in PG medical courses unconstitutional under Article 14 and reaffirmed that citizens have one domicile—India, not a separate State domicile. Reasonable institutional preference was distinguished and ongoing admissions were protected.

Reasoning adopted by the Supreme Court: The Court interpreted Medical Council/NMC postgraduate admission regulations and Chandigarh prospectus consistently with Articles 5, 14, 15 and 16 and applied Single Indian domicile; merit; residence reservation. It examined jurisdiction and legislative or statutory authority, compliance with natural justice, relevance and sufficiency of the material, proportionality of the measure and the practical consequences of the proposed rule. Where appropriate, the Court distinguished merits from procedure, individual relief from general directions, and binding ratio from observations limited to the facts.

Result for the parties: The operative directions in C.A. No. 9289/2019 determine TANVI BEHL vs SHREY GOEL. The relief granted or refused, and any remand, bail condition, prospective operation, monitoring requirement, time limit, compensation rule or preservation of earlier proceedings, must be understood as part of the final outcome described above.

Broader legal significance: The ruling guides courts, legislatures, governments, investigators, regulators, employers or private parties confronting materially similar issues. Its scope remains subject to the qualifications expressed by the bench; where this summary and the signed decision differ, the official judgment and operative paragraphs are controlling.

Statutory Provisions / Acts Involved

Medical Council/NMC postgraduate admission regulations and Chandigarh prospectus

Articles of the Constitution of India Involved

Articles 5, 14, 15 and 16

Legal Principles

Single Indian domicile; merit; residence reservation

Neutral Citation

2025 INSC 125

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