SUPREME COURT UPHOLDS TELANGANA DOMICILE RULE REQUIRING 4 YEARS OF CONTINUOUS STUDY, ALLOWS RELAXATION FOR CHILDREN OF GOVERNMENT EMPLOYEES:

The Supreme Court of India has upheld the validity of Telangana’s domicile rule, which requires candidates seeking admission to medical and dental colleges under the local quota to have studied in the state for four consecutive years. The ruling came in an appeal filed by the State of Telangana challenging a judgment of the Telangana High Court, which had previously held that permanent residents of the state could not be compelled to meet the requirement of continuous study or residence to qualify for the domicile quota.

A bench comprising Chief Justice of India B.R. Gavai and Justice K. Vinod Chandran ruled in favor of the state, upholding the 2017 Telangana Medical and Dental Colleges Admission Rules. These rules stipulate that a candidate must study in Telangana for four successive academic years to be treated as a “local candidate” and avail the 85 percent quota reserved for such students in MBBS and BDS admissions. The Court observed that the provision was consistent with the Presidential Order issued under Article 371D of the Constitution, which empowers states like Telangana to frame rules granting preferential treatment to local candidates in matters of education and public employment.

The petitioners before the High Court had argued that the rules unfairly excluded permanent residents who, due to the employment of their parents, were compelled to study outside the state. They contended that the rigid definition of a local candidate did not account for the vagaries of life, particularly transfers of parents working in All India Services, the armed forces, public sector undertakings, or state corporations. The High Court accepted this reasoning, “reading down” Rule 3(a) and Rule 3(iii) of the 2017 Rules to exclude permanent residents from the requirement of four consecutive years of study or residence. It also directed the state to frame guidelines for identifying permanent residents.

The State of Telangana, however, argued that it was competent to prescribe a test of residence or study to determine who could be considered a local candidate. The government emphasized that the rule was framed to benefit marginalized students who lacked the financial capacity to pursue coaching or education outside the state. To address genuine hardships faced by children of employees liable to transfers, the state introduced an amendment through G.O. No. 33 dated July 19, 2024. The amendment carved out specific relaxations for children of Telangana government employees, members of All India Services belonging to the Telangana cadre, defence and central armed police force personnel, and employees of state corporations whose service required them to work outside Telangana. These candidates, even if they studied outside the state for part of the requisite four-year period, would remain eligible for consideration as local candidates, subject to documentary proof of their parents’ service.

The Supreme Court accepted this amendment and upheld the rules as modified. Justice Chandran, writing for the bench, observed that the earlier definition of a local candidate under the unamended rules had already been held valid, and the same reasoning extended to the amended version. The Court noted that there was no necessity for the High Court to dilute or reinterpret the definition, as it was clear, consistent with the Presidential Order, and supported by binding precedents. Since 15 percent of seats are already earmarked for the All India Quota, the Court concluded that the local quota rules for Telangana were constitutionally valid and legally sustainable.

By overturning the High Court’s judgment, the Supreme Court reaffirmed the state’s authority to prescribe domicile-based criteria in medical admissions, while also recognizing the legitimate concerns of children of transferable employees through narrowly tailored exceptions.