Supreme Court Upholds State Rules Defining “Local Candidate” For Medical Seats, Narrows High Court Expansion

A Bench of Chief Justice B.R. Gavai and Justice K. Vinod Chandran heard appeals against High Court orders that had expanded the definition of a “local candidate” for allocation of Competent Authority (state quota) seats in MBBS/BDS courses. The appeals arose from challenges to the Telangana Medical & Dental Colleges Admission (Admission into MBBS & BDS Courses) Rules, 2017 and an amendment by G.O. Ms. No.33 dated 19.07.2024, and raised the question whether a High Court could, under Article 226, expand a legislative definition framed in consonance with a Presidential Order under Article 371D.

The Court allowed the State’s appeals, set aside the High Court judgments and upheld the Rules of 2017 as amended in 2024, subject to a narrowly tailored proviso protecting certain categories of candidates whose parents were posted outside Telangana by reason of employment. The Court held that the Rules were traceable to the Presidential Order under Article 371D and to the State’s rule-making power in the field of education under Entries in the Seventh Schedule read with Articles 245 and 246, and therefore were not liable to be read down as the High Court had done. The Court, in its reasoning, observed: The Court also quoted the principle that “equality must not remain mere idle incantation, but it must become a living reality for the large masses of people,” to underline the legislative aim of affirmative classification in admissions. The Court directed that admissions already made on the consent of the State pursuant to the High Court orders “shall not be disturbed.”

Background The dispute began with two batches of writ petitions in the Telangana High Court: the first challenged the Rules of 2017 (judgment dated 29.08.2023) and the second challenged the amendment by G.O. Ms. No.33/19.07.2024 (judgment dated 05.09.2024). The High Court found that the Rules were made under the Telangana Admission Act, 1983 and not under the Presidential Order issued under Article 371D, and expanded the definition of “local candidate” to permit candidates to qualify by producing residence certificates issued by competent authorities. Petitioners were varied in fact patterns; some had studied in Telangana for early school years but completed higher secondary outside the State. The State and the university contended that the High Court’s expansion would frustrate the special scheme under Article 371D intended to confer preferential admission to students genuinely integrated into the local environment and likely to serve within the State after qualification.

Relying on constitutional principles governing legislative competence and a line of precedents upholding domicile/residence-linked reservation in admissions (including D.P. Joshi, Kumari N. Vasundara, Pradeep Jain and later authorities), the Supreme Court concluded that the Presidential Order and the Admission Act empowered the State to define local areas and local candidates and to make consequential rules. The Court rejected the High Court’s reading down of the Rules as unnecessary and potentially unworkable, but accepted a specific mitigating proviso proposed by the State to cover children of State employees, All-India Service officers of the State cadre, defence and paramilitary personnel and employees of State instrumentalities who served outside Telangana during the relevant years; such candidates were to produce competent authority certificates of parental service for the corresponding period. The appeals were allowed, the writ petitions and connected SLPs were dismissed subject to that proviso, no costs were imposed, and pending applications were disposed of. The Court made clear that previously permitted admissions made on concession would remain protected.

Case Details: Case No.: 2025 INSC 1058 Case Title: The State of Telangana & Ors. Etc. Versus Kalluri Naga Narasimha Abhiram & Ors. Etc. Appearances: For the Petitioner(s): Dr. Abhishek Manu Singhvi, Senior Counsel; Mr. Gopal Sankarnarayanan, Senior Counsel; Mr. A. Sudarshan Reddy, Advocate General for Telangana For the Respondent(s): Mr. P.B. Suresh, Senior Counsel; Mr. Raghenth Basant, Senior Counsel; Mr. Prakash Deu Naik, Senior Counsel; Mr. Krishna Dev Jagarlamudi, Counsel (Also appeared: Mr. S. Sriram, Senior Counsel for impleader)