Case Summary: Dr. Preeti Srivastava vs State of M.P. (1999)
📌 CASE STATS
Case Title: Dr. Preeti Srivastava and Another vs State of M.P. and Others
Date of Decision: 10-08-1999
Court: Supreme Court of India
Bench: Full Bench (A.S. Anand, V.N. Khare, Sujata V. Manohar, S.B. Majmudar, K. Venkataswami)
Citation: AIR 1999 SC 2894; (1999) 7 SCC 120; (1999) AIRSCW 2795; (1999) 5 JT 498; (1999) 4 SCALE 579
Final Decision: Allowed
[Judgment Source] https://www.courtkutchehry.com/Judgement/Search/AdvancedV2?docid=264949
⚖️ Law Points Raised
- Can States prescribe lower qualifying marks for reserved category candidates in Post-Graduate medical admissions?
- Whether such classification violates Articles 14, 15(1), and 15(4) of the Constitution?
- Interpretation of 'special provisions' under Article 15(4) and 'efficiency' under Article 335.
📚 Ratio Decidendi
- The State cannot wholly waive minimum qualifying marks for reserved category candidates in PG medical admissions.
- Article 15(4) allows special provisions but not at the cost of merit and efficiency in higher education.
- Reservation must be balanced with the constitutional mandate of maintaining academic standards and administrative efficiency.
✅ Final Ruling
- Supreme Court upheld the need for minimum qualifying marks for all categories.
- Struck down any policy or law prescribing zero or extremely low qualifying marks for PG medical admission.
- Directed that while reservation is valid, academic excellence and minimum standards cannot be diluted.
🔍 Relevant Paragraph Numbers
- 2 – Key constitutional question framed.
- 4–7 – Evolution of G.O.s regarding minimum qualifying marks.
- 10 – Core issue distilled.
- 11–12 – Detailed constitutional analysis under Articles 14, 15(4), 335.
- Final – Conclusion and directives.
📝 Case Summary
In this landmark judgment, the Supreme Court examined the legality of prescribing lower or no minimum qualifying marks for reserved category candidates in postgraduate medical education. The Court held that while reservations are permitted under Article 15(4), they cannot come at the cost of academic merit and efficiency. The Court emphasized the need for minimum standards even within reservation categories to maintain the quality of postgraduate education, and struck down any provision that removed or drastically reduced such standards.
[Judgment Source] https://www.courtkutchehry.com/Judgement/Search/AdvancedV2?docid=26494