Chhattisgarh High Court Strikes Down PG Medical Admission Rules, Says State Cannot Prioritise Local MBBS Graduates Over Others After NEET-PG

By Vivek G. • November 25, 2025

Dr. Samriddhi Dubey vs. State of Chhattisgarh & Others, Chhattisgarh High Court strikes down PG medical admission rules favoring local MBBS graduates, holding them unconstitutional and discriminatory under Article 14.

Bilaspur, Nov 20- The Chhattisgarh High Court on Wednesday set aside two controversial rules that determined priority in admissions to postgraduate medical seats. Inside Courtroom No. 1, the atmosphere was tense; several lawyers whispered about the NEET-PG counselling schedule, already underway. After a brief pause, Chief Justice Ramesh Sinha read out the order, making it clear that “merit, not geography,” must guide PG medical admissions in the State.

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Background

The petition was filed by 25-year-old Dr. Samriddhi Dubey, a Bilaspur resident who completed her MBBS from a college in Tamil Nadu. Despite clearing NEET-PG 2025, she claimed she was pushed to the back of the line in Chhattisgarh’s State quota counselling because Rule 11(a) and 11(b) of the 2025 PG Admission Rules gave first preference to students who earned their MBBS degrees within the State.

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Her senior counsel argued that this “institution-based preference” was merely domicile reservation in disguise, making students like her second-class applicants in their own home State. “This creates an artificial wall between two equally placed students,” he told the bench.

Court’s Observations

The Division Bench of Chief Justice Ramesh Sinha and Justice Bibhu Datta Guru relied heavily on the Supreme Court’s recent decision in Dr. Tanvi Behl v. Shrey Goel, which struck down residence-based preferences in postgraduate medical admissions.

At one point, Chief Justice Sinha remarked, “The bench observed, ‘PG medical education shapes specialised healthcare. Denying equal opportunity only because someone studied elsewhere is constitutionally suspect.’

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The judges also noted that several students admitted under All India Quota in Chhattisgarh medical colleges are originally from other States. So giving absolute preference to only Chhattisgarh-trained MBBS graduates was discriminatory and not backed by any compelling public interest.

The court appeared unconvinced by the State’s argument that the rule was institution-based and not residency-based. Instead, the judges hinted that it operated as a “backdoor reservation” favouring local candidates, ultimately violating Article 14 -the right to equality.

Decision

In a crisp conclusion lasting less than two minutes, the bench declared Rule 11(a) and 11(b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025 “ultra vires and violative of Article 14.” The High Court ordered the State not to distinguish between candidates who completed MBBS inside or outside Chhattisgarh, so long as they meet NEET-PG eligibility.

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With that, the writ petition was allowed - no costs, no further directions. Counselling authorities will now have to follow merit alone while filling State quota seats.

Case Title: Dr. Samriddhi Dubey vs. State of Chhattisgarh & Others

Case No.: WPC No. 5937 of 2025

Case Type: Writ Petition (Civil) under Article 226

Decision Date: 20 November 2025

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