79% Reservation in MBBS Admissions? Allahabad High Court Quashes UP Govt Orders

The Allahabad high court has quashed a series of Uttar Pradesh government orders that had fixed an unusually large quota in four government medical colleges, finding that the state had no legal authority to push reservation levels beyond the statutory ceiling. 

Court ordered seats to be refilled strictly in accordance with the Uttar Pradesh Admission to Educational Institutions Reservation for Scheduled Castes, Scheduled Tribes and Other Backward Classes Act, 2006 (the Reservation Act, 2006).

The petition, filed by NEET-2025 candidate Sabra Ahmad, challenged a seat matrix for the government medical colleges at Ambedkar Nagar, Kannauj, Jalaun (Orai) and Saharanpur. The matrix showed that when central (15 per cent) and state quotas were combined the effect was to reduce merit seats sharply and to inflate reserved allocations to levels the court said could reach nearly 79 per cent in the affected colleges.

The petitioner told the court she had secured 523 marks in NEET-2025 (All India rank 29,061) and that the enlarged reservation structure would materially affect her chances of admission; she had also made a representation to the state before moving the court.

State counsel defended the matrix by pointing to government orders issued while the colleges were established. The state argued that the medical colleges at Jalaun, Ambedkar Nagar, Kannauj and Saharanpur were set up under Central grants given through the Special Component Plan (SCP). The government orders linked to these grants required a 70% quota for SC/ST students, 15% for OBCs and only 15% for the general category, which is why the seat matrix showed such high reservation.

Taking note of the same, court noted, "The entire exercise of providing reservations to the extent mentioned above the reasoning and foundation is that funds were received for establishing these colleges under the Special Component Plan which contained a stipulation the funds received under the said plan had to be used so as to benefit 70% of boys and girls of SC/ST and 30% for general population. In the light of said, the State Government has tried to justify the reservation exceeding 50%".

However, court emphasised that the Uttar Pradesh Admission to Educational Institutions Reservation for SCs, STs and OBCs Act, 2006 prescribes fixed percentages at admission, that is 21 per cent for SC, 2 per cent for ST and 27 per cent for OBC, and that the rule limiting overall reservation to roughly 50 per cent, as explained in Indra Sawhney and subsequent jurisprudence, cannot be breached without lawful authority.

The bench of Justice Pankaj Bhatia highlighted that the impugned government orders fixing inflated quotas were not issued under the 2006 Reservation Act. They were only based on Central policy guidelines for implementing the Special Component Plan (SCP), which was meant for facilities like sports halls, colleges, or training for competitive exams, not for altering reservation in medical admissions.

Court, thus, concluded that the policy guidance for SCP-related infrastructure and hostel benefits did not, and could not, authorise the state to fix vertical reservation at the admission stage in contradiction of the statutory scheme.

Court further recorded that counsel for respondent No.2 (the admissions authority) relied on the Indra Sawhney judgment to argue that the 50% cap on reservations is not absolute. But he admitted that any breach must be backed by law, and he could not show any statute or legal provision allowing such an exception in this case.

As a result, the high court quashed six government orders that had prescribed the impugned quota structure which were orders dated 20 January 2010, 21 February 2011, 13 July 2011, 19 July 2012, 17 July 2013 and 13 June 2015.  Court held that those orders were not issued under the Reservation Act of 2006 and were therefore without legal foundation.

Court directed the state to undertake a fresh exercise to fill the seats in the four colleges strictly in accordance with the Reservation Act, 2006, while also accommodating the central quota seats where applicable.

Because the seats for the relevant academic cycles had already been filled, respondent No.2 (the admissions authority) was ordered to redo the admissions process to conform to the statutory reservation scheme.

Case Title: Sabra Ahmad v. State of U.P. & Ors.

Order Date: August 25, 2025

Bench: Justice Pankaj Bhatia