The Supreme Court recently gave its judgment in a batch of appeals relating to the definition of a "local candidate" for medical and dental college admissions in Telangana. The main point was whether the High Court could interfere with, enlarge, or modify the definition of "local candidate" drawn by the State under its rules, which were consistent with a Presidential Order made under Article 371D of the Constitution.
The Court favored the Telangana government, reinstating the initial rules and nullifying the directions of the High Court that had extended the definition of local candidature.
Background:
Article 371D was enacted in the Constitution to provide an even opportunity for education and employment in the erstwhile state of Andhra Pradesh. Following the bifurcation in 2014, the provision was made applicable to Andhra Pradesh and Telangana for a period of ten years. In consonance with this, the Andhra Pradesh Educational Institutions (Regulation of Admissions) Order, 1974—referred to as the Presidential Order—carved out the state into local areas and stipulated who would qualify as a local candidate on the basis of study or residence.
Telangana drafted the Medical and Dental Colleges Admission Rules in 2017 (subsequently amended in 2024) to govern admissions under the "Competent Authority Quota." These rules, in effect, adhered to the Presidential Order's stipulations on determining local candidates. Students not happy with the strict requirements, however, approached the High Court against these provisions.
The High Court's Stand:
The Telangana High Court ruled that the strict definition of local candidates was discriminatory to students whose parents were forced to relocate outside the state on grounds of transfers, jobs, or better studies. It declared the rules as arbitrary under Article 14 of the Constitution (equality of opportunity).
To correct this, the High Court ordered that students could also be treated as local candidates on the basis of residence certificates, thus broadening the definition considerably. The State challenged this interpretation by contending that such an expansion was against the special provisions of Article 371D.
Supreme Court's Reasoning:
The Supreme Court examined the issue thoroughly, considering the background of Article 371D and previous judgments like D.P. Joshi v. State of Madhya Bharat, Pradeep Jain v. Union of India, and Anand Madaan v. State of Haryana.
It observed that:
- The Telangana rules had their genesis directly in the Constitution under Article 371D and the 1974 Presidential Order.
- The intention behind characterizing local candidates in terms of residence and education within the state was to do justice to students who are actually well integrated into the atmosphere of Telangana and are more likely to serve the state upon completion of medical education.
- Although difficulties might arise in some cases, that by itself cannot render a rule unconstitutional unless it is grossly arbitrary, discriminatory, or irrational.
The Court emphasized that policy-making, particularly in educational reservations, falls into the domain of the legislature and the executive, not for the judiciary to enlarge through interpretation.
Relief for Certain Categories:
Considering there were real hardships, the State conveyed to the Court its intention to introduce a proviso to the rules. The proviso provides relaxation for children of:
- Telangana government servants working outside the state,
- All India Service officers of the Telangana cadre serving outside the state,
- Defense or paramilitary staff who have opted Telangana as their home state,
- State corporation employees subject to transfers outside Telangana.
All such students, if forced to study outside the state based on their parents' employment, would still be considered eligible for local candidate consideration upon submitting required certificates. The Supreme Court ratified this step as an equalizing measure.
The Final Verdict:
The Supreme Court overruled both High Court judgments that had widened the meaning of local candidates. It confirmed the 2017 rules as modified in 2024, and the mooted proviso to reduce hardships in deserving cases.
The Court also made it clear that admissions already made on the expanded definition during litigation would not be revoked, but henceforth only the rules as confirmed would be followed.
Through this decision, the Supreme Court reiterated that the High Court cannot reframe legislative or executive policy on admissions, particularly when the structure is based on constitutional provisions such as Article 371D.
