Article 14 | ‘Rules of the Game Cannot Be Changed Midstream’: Supreme Court Quashes Punjab’s Modified Sports Quota Policy for MBBS Admissions

“Just as modification of recruitment norms is forbidden in law after the recruitment process has begun, it is equally illegal for an admission process to not be fully defined in all its contours before its commencement, so as to leave room for the authorities concerned to stipulate norms later on to suit their own interests or to permit nepotism.”— In a seminal ruling the Supreme Court of India, comprising Justice Sanjay Kumar and Justice Alok Aradhe, has quashed the modification of the Sports Quota admission criteria for MBBS/BDS courses in Punjab for the academic session 2024, terming it arbitrary and vitiated by fraud and conflict of interest.

The Controversy: Changing Rules After the Game Began

The appeals, led by Divjot Sekhon, challenged the actions of the State of Punjab and Baba Farid University of Health Sciences. The core grievance was the alteration of eligibility criteria for the Sports Quota after the issuance of the prospectus for NEET UG-2024. Initially, the prospectus and prevailing norms stipulated that credit for sports achievements would be restricted to Classes XI and XII. However, following an email dated August 16, 2024, the University expanded the zone of consideration to include achievements from Classes IX and X as well.

The Appellants contended that this mid-stream change diluted their merit. Consequently, candidates with achievements in lower classes (IX and X) leapfrogged over them in the merit list. The Court observed that while a similar relaxation was granted in 2023, it was a one-time exception due to the COVID-19 pandemic and could not be perpetuated as a norm for 2024 without prior notification.

“The transparency of such a process is paramount to ensure fairness and prevent arbitrariness.”

The ‘Subterfuge’: Undisclosed Conflict of Interest

In a startling revelation, the Supreme Court unearthed that the policy change was triggered by a representation from one Ramesh Kumar Kashyap, a Roller-Skating Coach. The Court found that Kashyap had petitioned the authorities to include Class IX and X achievements, ostensibly for the benefit of all athletes. However, he concealed a critical material fact: his own daughter, Kudrat Kashyap (Respondent No. 4), stood to be the direct beneficiary of this change.

Following the policy modification, Kudrat Kashyap secured Rank No. 1 in the sports merit list. The Bench came down heavily on this conduct, noting that the State acted on this representation without being aware of the underlying motive. The Court held that this "lack of probity" and the "machinations" to benefit a specific candidate vitiated the entire policy modification.

“This lack of probity on the part of Ramesh Kumar Kashyap, so as to benefit his own daughter, and his influencing of the authorities without disclosing this fact... is sufficient in itself to vitiate the modification.”

Violation of Article 14 and Administrative Fairness

The Court reiterated the settled legal principle that "the rules of the game cannot be changed after the game has begun." Relying on precedents like Maharashtra SRTC v. Rajendra Bhimrao Mandve and K. Manjusree v. State of A.P., the Bench held that admission criteria must be fixed before the process commences.

The Court criticized the State of Punjab for maintaining "opaque flexibility" in its admission norms, which allowed for arbitrariness and nepotism to creep in. The Bench observed that while the State has the power to formulate policy, it cannot do so whimsically or to suit private interests mid-process. The failure to disclose the exact policy regarding the zone of consideration at the outset was held to be violative of the principles of fair play and Article 14 of the Constitution.

“Lack of transparency at the outset invariably enables and makes room for arbitrariness and nepotism to walk in through the backdoor, a situation to be eschewed and avoided by an egalitarian State.”

Unusual Relief: The ‘Seat Swap’ Direction

Recognizing that a complete redraw of the merit list would disrupt the academic session for many students not before the Court, the Bench moulded the relief specifically for the litigants. The Court directed a swapping of seats:

1. The Appellants (Divjot Sekhon and Shubhkarman Singh), who were forced into private colleges, are to be accommodated in the Government Medical College seats currently held by the beneficiaries of the tainted policy.

2. Conversely, the beneficiaries (Kudrat Kashyap and Mansirat Kaur) are to be shifted to the private college seats vacated by the Appellants.

3. The Court clarified that the studies and fees already paid would remain undisturbed, effectively penalizing the beneficiaries of the fraud without cancelling their admissions entirely.

Regarding the challenge for the 2025 session, the Court granted liberty to the aspirants to approach the High Court with a fresh petition, impleading all necessary parties, as the 2025 admissions had already concluded and affected candidates were not present in the current proceedings.

Date of Decision: 06/01/2026