Andhra Pradesh High Court Upholds Compartmentalized Horizontal Reservation in Sports Quota for MBBS Admissions

Sports Quota Is Only A Horizontal Reservation And Not A Vertical Reservation Which Can Be Treated As A Separate Silo — AP High Court 

On April 3, 2025, a Division Bench of the Andhra Pradesh High Court, comprising Hon'ble Chief Justice Dhiraj Singh 
Thakur and Hon'ble Justice R. Raghunandan Rao, pronounced an important judgment in Shanmukha Kanaka Priya Chinta vs. The State of Andhra Pradesh & Others, W.P. No. 10783 of 2022. The Court upheld the validity of compartmentalized horizontal reservation within the sports quota for MBBS admissions under the Andhra Pradesh Unaided Non-Minority Professional Institutions (Regulation of Admissions into Undergraduate Medical and Dental Professional Courses) Rules, 2007. The Court rejected the petitioner’s challenge against the sub-division of the sports quota on the basis of community, clarifying that such reservation does not amount to “reservation within reservation.” 
 
The petitioner, Shanmukha Kanaka Priya Chinta, appeared for NEET 2021 and secured Rank No. 654334. She applied for admission under the sports quota based on her performance in Handball but failed to secure a seat under this category. She subsequently joined respondent No.21-college under the management quota but later challenged the allotment of seats alleging that candidates with lower merit, such as respondent No.18 (priority 146), were preferred over her (priority 92) under the sports quota, violating merit and reservation rules. 
 
The petitioner primarily objected to the compartmentalization of sports quota seats among OC, BC, SC, and ST candidates, contending that such sub-classification amounts to a "reservation within reservation" which is impermissible. 

The core issue before the Court was: 
Whether the sub-classification of sports quota seats based on community is valid or amounts to reservation within reservation? 

The petitioner relied on the case of P. Srividya vs. State of Andhra Pradesh, AIR 2008 AP 109, asserting that sports quota should be a standalone reservation without further subdivision based on community. 
 
However, the respondent-University argued that:  “Sports quota is a horizontal reservation and not a vertical reservation which can be treated as a separate silo for allotment of seats.”  and relied upon G.O.Ms.No.231 dated 11.07.2007, which explicitly provides for compartmentalization of sports quota among OC, BC, SC, and ST categories. 
  
The Court reaffirmed:  “In those circumstances, the contention of the learned counsel for the petitioner that distribution of sports quota seats among various social groups is not permissible, has to be rejected.” 
  
Referring to the Supreme Court’s judgment in Indra Sawhney vs. Union of India, 1992 Supp (3) SCC 217, and the Division Bench decision in P. Srividya, the High Court clarified that horizontal reservations must be proportionally distributed across social categories. 
 
The Bench meticulously analyzed: 
 
•    G.O.Ms.No.136 and G.O.Ms.No.231, confirming that sports quota falls under horizontal reservation. 

•    The absence of any violation of merit since no less meritorious OC candidate was granted a seat. 

•    The petitioner’s OC category status and the fact that no OC category seat under sports quota was available in respondent No.21-college. 

The Court observed:  "The petitioner, even if she was eligible otherwise, would not have been granted a seat in respondent No.21college." 

The Court further noted:  "The petitioner would have a case if she could point to any other sports person in the open category, who was allotted a seat even though he/she was less meritorious than the petitioner. The petitioner does not make out any such case." 
 
The Andhra Pradesh High Court upheld the validity of compartmentalized horizontal reservation in sports quota, dismissing the writ petition as devoid of merit. The Court reinforced the principle that horizontal reservations like sports quota must be distributed among all social categories and cannot be treated as a standalone vertical reservation. 
 
Date of Decision: 03/04/2025