State Can Create In-Service Quota In PG Medical Courses Without Mandating Prior Rural Service As Condition Precedent: Punjab & Haryana High Court

"The doctors in employment of the States and allied sectors form a separate and distinct class and for the purpose of admission in postgraduate degree courses they can be given certain elements of preference." Punjab and Haryana High Court, in a significant ruling, held that the State Government possesses the legislative competence to create a separate entry channel for in-service doctors in postgraduate medical courses without making prior rural service a mandatory condition precedent for admission.

A bench of Acting Chief Justice Ashwani Kumar Mishra and Justice Rohit Kapoor observed that the State's policy of requiring a post-admission bond to serve in rural areas for five years sufficiently fulfills the constitutional objective of strengthening rural healthcare.

The petitioners, qualified medical professionals holding MBBS degrees, challenged the Haryana Government notifications dated September 2, 2024, and July 25, 2024, which allocated a 40% State quota for in-service doctors in postgraduate medical courses. They argued that an in-service quota could only be restricted to doctors who had already rendered a minimum of two years of service in rural, remote, or difficult areas. The petitioners contended that the absence of prior rural service as an eligibility criterion rendered the policy arbitrary and violative of the Supreme Court's directives in the Constitution Bench judgment of Tamil Nadu Medical Officers Association v. Union of India.

The primary question before the court was whether prior service in rural, remote, or difficult areas is a mandatory condition precedent for admission to postgraduate courses under the in-service quota. The court was also called upon to determine the validity of the distinction drawn between in-service doctors who had rendered prior rural service and those who had not.

State Possesses Legislative Competence Under Entry 25 List III

The court examined the constitutional distribution of legislative powers and noted that the State's authority to carve out a separate channel of admission for in-service doctors flows from Entry 25 of List III of the Seventh Schedule. Citing the Supreme Court Constitution Bench ruling in Modern Dental College & Research Centre v. State of M.P., the bench reiterated that the field of medical education is within the concurrent domain, and State legislation or executive policy in this regard does not encroach upon Parliamentary enactments or Central regulations.

"The State, therefore, would be well within its jurisdiction to issue executive instructions, thereby providing a separate channel of entry for its in-service doctors to the PG medical courses."

In-Service Doctors Form A Distinct Class

The bench underscored that in-service medical professionals form a distinct class entitled to institutional preferences. Referring to the landmark Constitution Bench ruling in Tamil Nadu Medical Officers Association v. Union of India, the court noted that allocation of seats for in-service candidates is an exclusive channel of entry rather than a reservation under the constitutional scheme of compensatory discrimination.

"Holding them to be a distinct group fits in with overall objective of having medical professionals with superior qualification for tending to the needs of the general public."

Prior Rural Service Not A Precondition For Quota Eligibility

Addressing the core challenge regarding paragraph 97 of the Tamil Nadu Medical Officers Association judgment, the court clarified that observations made by the Supreme Court regarding prior rural service pertained to specific statutory instruments under consideration rather than erecting an absolute constitutional bar. The bench held that the State policy adequately secures the objective of public healthcare by mandating that all beneficiaries execute a bond to serve in rural and difficult areas for five years post-completion of their postgraduate studies.

"The object of the State policy is to provide better medical facilities to the common masses in the State. Such objective is adequately achieved by the doctors executing the requisite bond to serve in such rural/remote/difficult areas for a period of five years."

Valid Classification Between Two Categories Of In-Service Doctors

The court evaluated the differential treatment meted out under the policy between doctors who had completed two years of rural service and those who had not. Doctors with prior rural service are granted full salary during their postgraduate studies, whereas those without such prior service are granted study leave without pay alongside the protection of service continuity. The bench held that this classification is founded on an intelligible differentia bearing a direct rational nexus with the objective of incentivizing and rewarding rural healthcare service.

"The distinction drawn between two sets of in-service doctors is based on intelligible differentia and has specific object to achieve i.e., providing of improved medical facilities in rural/difficult areas."

Final Directions And Order

Finding no infraction of Article 14, Article 254, or any other constitutional provision, the High Court upheld the validity of the notification dated September 2, 2024. The writ petition was accordingly dismissed along with all pending miscellaneous applications.

The judgment firmly establishes that States possess wide administrative latitude in structuring postgraduate medical admission policies for in-service personnel. By validating post-admission rural service bonds over pre-admission mandatory rural service, the ruling balances the career aspirations of government doctors with the pressing demands of public healthcare delivery in remote regions.

Date of Decision: 04 August 2026