Supreme Court Limits State Residency Quota in B.Ed Admissions: Veena Vadini Teachers Training Institute vs. State of Madhya Pradesh (28 April 2023)

Introduction

Date of the Judgment: 28 April 2023
Citation: 2023 INSC 380
Judges: Justice Dinesh Maheshwari and Justice Sudhanshu Dhulia. The judgment was authored by Justice Sudhanshu Dhulia.

Can a state government reserve a large portion of seats in educational institutions for its residents, even if it leads to many seats remaining vacant? The Supreme Court of India recently addressed this question in a case concerning admissions to B.Ed (Bachelor of Education) courses in Madhya Pradesh. The core issue was the validity of a state policy that reserved 75% of B.Ed seats for residents of Madhya Pradesh, leaving only 25% for candidates from other states. The Court examined whether such a high reservation percentage was justified and consistent with the principles of equality.

Case Background

Veena Vadini Teachers Training Institute, an educational institution in Madhya Pradesh, challenged the state government’s admission policy for B.Ed courses. The policy, “Admission Process and Guiding Principles 2022-2023,” reserved 75% of the seats for residents of Madhya Pradesh and only 25% for candidates from other states. The institute argued that this policy was unconstitutional and led to a significant number of seats remaining vacant because there were not enough resident candidates to fill them. The institute highlighted that while the 25% quota for outside candidates was almost fully utilized, most of the 75% reserved seats for residents remained unfilled.

Timeline

Course of Proceedings

The appellant, Veena Vadini Teachers Training Institute, initially filed a writ petition in the Madhya Pradesh High Court challenging the government policy dated 12.05.2022. The High Court dismissed the petition, relying on an earlier decision in Preston College and Another v. State of M.P. & Ors., which had upheld residential requirements for admissions. The appellant then appealed to the Supreme Court of India. The Supreme Court granted leave to appeal and heard the matter.

Legal Framework

The case primarily involves the interpretation of Article 14 of the Constitution of India, which guarantees equality before the law. The Supreme Court also considered previous judgments on reservations based on residence, particularly in the context of medical education. The key legal provisions and principles discussed include:

• Article 14 of the Constitution of India: Guarantees equality before the law and equal protection of the laws within the territory of India.
• Previous Judgments: The Court referred to Dr. Pradeep Jain and Others v. Union of India and Others (1984) 3 SCC 654, D.P. Joshi v. State of Madhya Pradesh (1955) 1 SCR 1215, Saurabh Chaudhari and Others. v. Union of India and Others (2003) 11 SCC 146, Magan Mehrotra and Others v. Union of India and Others (2003) 11 SCC 186 and Rajdeep Ghosh v. The State of Assam (2018) 17 SCC 524, which had upheld the validity of residence-based reservations in medical education, subject to certain limitations.

Arguments

Appellant’s Arguments:

• The appellant argued that the state government’s policy reserving 75% of B.Ed seats for residents of Madhya Pradesh was unconstitutional and violated Articles 14, 15, and 19(1)(g) of the Constitution.
• They contended that the policy led to a large number of seats remaining vacant, as there were not enough resident candidates to fill them.
• The appellant highlighted that while the 25% quota for outside candidates was almost fully utilized, most of the 75% reserved seats for residents remained unfilled.
• They sought permission to fill the vacant seats with candidates from outside Madhya Pradesh, which was not allowed under the policy.

Respondent’s Arguments:

• The State of Madhya Pradesh defended its policy, arguing that it was within its right to reserve seats for its residents.
• The state relied on earlier judgments that had upheld residence-based reservations in medical education.
• The state argued that the policy was aimed at promoting the interests of the residents of Madhya Pradesh, considering the state’s investments in educational infrastructure.

Issues Framed by the Supreme Court

The Supreme Court framed the following issues:

1. Whether the State Government can reserve seats for “residents” of Madhya Pradesh in B.Ed courses.
2. If such reservation is permissible, whether reserving 75% of the total seats for residents is justified.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues:

Authorities

The Supreme Court considered the following authorities:

Judgment

How each authority was viewed by the Court?

• The court relied on D.P. Joshi v. State of Madhya Pradesh [1955] 1 SCR 1215* to acknowledge the principle that the State can classify students based on residence for fee structure and admission.
• The court extensively relied on Dr. Pradeep Jain and Others v. Union of India and Others [1984] 3 SCC 654* to uphold the principle of residence-based reservations, but also to emphasize that “wholesale” reservations are unconstitutional. The court used the 70% outer limit for residence-based reservations, as mentioned in the Pradeep Jain judgment.
• The court also noted Saurabh Chaudhari and Others. v. Union of India and Others [2003] 11 SCC 146*, Magan Mehrotra and Others v. Union of India and Others [2003] 11 SCC 186* and Rajdeep Ghosh v. The State of Assam [2018] 17 SCC 524* that followed the ratio of Pradeep Jain.

What weighed in the mind of the Court?

The Supreme Court’s decision was influenced by several factors, including:

• The need to balance the state’s interest in providing education to its residents with the principle of equality.
• The fact that a 75% reservation for residents led to a significant number of seats remaining vacant, defeating the purpose of such a reservation.
• The Court’s concern that a large-scale reservation based on residence could be discriminatory and violate Article 14 of the Constitution.
• The need to ensure that educational opportunities are available to all, regardless of their place of residence.

Key Takeaways

• State governments can reserve seats in educational institutions for their residents, but such reservations must not be excessive.
• A reservation of 75% for residents is considered a “wholesale reservation” and is unconstitutional, violating Article 14 of the Constitution.
• The state must consider ground realities and the actual availability of resident candidates when determining the extent of such reservations.
• The Supreme Court has cautioned against large-scale residence-based reservations, emphasizing the need to balance state interest with equality.

Directions

The Supreme Court directed the State of Madhya Pradesh to re-evaluate its admission policy for B.Ed courses. The state was instructed to fix the number of seats for residents and non-residents, keeping in mind the observations made by the Court. The state was also directed to consider the data of the last few years to determine a realistic percentage for such reservations. This process had to be completed within two months from the date of the judgment.

Development of Law

The ratio decidendi of this case is that while residence-based reservations are permissible, they cannot be so excessive as to become “wholesale” reservations. The Supreme Court reiterated the principle established in Dr. Pradeep Jain that such reservations should not exceed 70% and that the state must consider the actual availability of resident candidates when determining the extent of such reservations. This judgment clarifies that the principles regarding residence-based reservations, initially laid down in the context of medical education, are also applicable to other professional courses like B.Ed. This case also emphasizes the need for states to balance their interest in providing education to their residents with the constitutional guarantee of equality.

Conclusion

The Supreme Court’s judgment in Veena Vadini Teachers Training Institute vs. State of Madhya Pradesh clarifies the permissible limits of residence-based reservations in educational institutions. While upholding the state’s right to reserve seats for its residents, the Court emphasized that such reservations should not be excessive and should not lead to a large number of seats remaining vacant. The Court directed the State of Madhya Pradesh to re-evaluate its policy and fix a reasonable percentage for resident and non-resident seats, thereby ensuring a balance between state interest and the principles of equality.