Sanchayita Lahkar

The High Court of Gauhati, Division Bench of Chief Justice Ashutosh Kumar and Justice Arun Dev Choudhury refused relief to a medical aspirant who had challenged the denial of admission to an MBBS seat allotted to the Nagaland Government under the Central Pool quota, despite having secured marks above the qualifying cut-off. The petitioner had questioned a 2021 State notification that made her ineligible for one of the 42 MBBS seats allocated to Nagaland, which a Single Judge had earlier quashed as inconsistent with the Central Government’s July 28 guidelines. Setting aside that decision, the Division Bench upheld the notification and dismissed her plea.

The case arose from a dispute concerning the eligibility of a medical aspirant for admission to an MBBS seat under the Central Pool quota allocated to the State of Nagaland. The petitioner, the ward of an Indian Army officer posted as Commanding Officer of 1 Nagaland Battalion NCC at Kohima, applied for admission to the MBBS course against one of the 42 seats allotted to Nagaland under the Central Pool scheme for the academic year 2025–2026. Her name did not appear in the merit list prepared by the Directorate of Technical Education, Nagaland, prompting her to approach the High Court through a writ petition.

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The petitioner contended that she had obtained marks above the cut-off and was eligible for nomination under the Central Pool quota. She challenged a government notification dated September 9, 2021, issued by the Nagaland Department of Higher and Technical Education, which disqualified her on the ground that wards of defence personnel were not eligible for the quota earmarked for the State. The petitioner argued that the notification was arbitrary and contrary to the guidelines issued by the Ministry of Health and Family Welfare on July 28, 2025, governing allocation of Central Pool MBBS/BDS seats. She maintained that, as the daughter of a serving Army officer stationed in Nagaland, she was entitled to be treated at par with Central Government employees posted in the State, as contemplated under Clauses 1.2.3 and 1.2.4 of the Central guidelines.

The State of Nagaland opposed the petition, asserting that the Central Pool seats allocated to the State were domicile-based and intended to benefit students of Nagaland, while a separate quota existed for defence personnel under the Central Pool. The Union of India, through a communication dated September 17, 2025, clarified that Army personnel were covered under a distinct defence quota and not under the deficient State quota meant for Nagaland. The parties relied on the Central Government’s guidelines and related communications to substantiate their respective interpretations of eligibility under the scheme.

The Court observed that the dispute centred on whether the petitioner, a ward of an Army officer, could claim eligibility for an MBBS seat under the Central Pool quota reserved for the State of Nagaland. It recorded that “the issue revolves around Clauses 1.2.3 and 1.2.4 of the guidelines mentioned above, and whether the petitioner is covered under the aforesaid Clauses, and whether her father shall come within the definition of an employee of the Central Government for the purpose of availing the benefit.”

Referring to the Union Government’s clarification, the Bench stated that “the seats under Clause 1.2.4 of the guideline dated 27.07.2025 are allocated to the State to compensate for the shortage of medical infrastructure and to provide opportunities for the students of the State to integrate into the mainstream, and already a separate quota is reserved for Army personnel.”

The Court noted that the Central Pool MBBS/BDS seats are administered by the Ministry of Health and Family Welfare, which distributes them among various beneficiary categories, and “the defence personnel quota and the deficient State quota are mutually independent and non-interchangeable sub-schemes under the overall Central Pool.” It recorded that “the object of the deficient State quota is to augment the supply of doctors in the State that lacks adequate medical colleges, and the object of the defence pool is entirely different; to recognise and reward national service by defence personnel.”

The Bench observed that “for the purpose of availing such benefit, a defence personnel cannot be treated as a Central Government employee,” and that “the guideline dated 28.07.2025 itself disqualifies the writ petitioner from getting the benefit of Central Pool MBBS seats meant for a deficient State.” It recorded that “the law also disfavours dual benefit under two different welfare schemes emanating from the same source.”

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The Court further observed that “it is well settled that a writ court cannot, in the exercise of its power of judicial review, compel the executive to merge or cross-apply distinct quota categories unless the exclusion is manifestly arbitrary, which it is not in the present case.” It added that “the learned Single Judge overlooked the foundational distinction between the two categories: these two quotas serve a distinct policy objective. When the Guidelines dated 28.07.2027 are not meant for the defence quota, the impugned notification dated 09.09.2021 does not offend the writ petitioner, and such a notification cannot be struck down as a whole at the behest of the writ petitioner.”

Finally, the Bench stated that “the judgments relied upon by the learned counsel for the writ petitioner, in the considered opinion of this Court, are not applicable in the given facts of the present case.”

The Division Bench held that “the writ appeal succeeds. The impugned common judgment and order dated 14.08.2025 passed by the learned Single Judge in WP(C) 134/2025 and WP(C) 138/2025 are set aside. The writ petitions stand dismissed

Advocates Representing the Parties:
For the Appellants: Ms. V. Suokhrie, Additional Advocate General, Nagaland; Ms. T. Khro, Additional Advocate General, Nagaland.
For the Respondents: Mr. K. Gogoi, Central Government Counsel; Mr. Akshay Bhandari, Advocate.

Case Title: The State of Nagaland and Others v. Vatsala Panghal and Another
Neutral Citation: 2025: GAU-AS:14150-DB
Case Number: WA/260/2025
Bench: Chief Justice Ashutosh Kumar and Justice Arun Dev Choudhury