1979 (1) TMI 239 - SC - Indian Laws

Summary

Issues Involved:
1. Discrimination in the distribution of seats among eligible students from different regions.
2. Validity of the selection process for medical college admissions.
3. University-wise allocation of seats.
4. Implementation of a uniform entrance examination.
5. Temporary solution for the current academic year.

Detailed Analysis:

1. Discrimination in the Distribution of Seats:
The High Court invalidated a transitory scheme of admission to the medical colleges of Kerala on the ground of discrimination in the distribution of seats among eligible students from two disparate regions of the State. The scheme was struck down due to the unequal allocation of seats, which led to confusion in the admission process. The Supreme Court recognized the historical academic disparity between the Travancore-Cochin and Malabar regions and acknowledged the State's efforts to address this imbalance by setting up institutions like the Calicut Medical College.

2. Validity of the Selection Process:
The High Court found the selection process discriminatory due to the unequal treatment of marks obtained by students from different universities. It stated that comparing marks from different universities with varying standards is not a proper mode of determining comparative merit. The Supreme Court, however, did not find substantial evidence to support the claim of significant differences in syllabi and evaluation standards between the Kerala and Calicut Universities. It emphasized that minor differences do not constitute discrimination under Article 14 of the Constitution.

3. University-wise Allocation of Seats:
The Supreme Court upheld the principle of university-wise allocation of seats as constitutionally valid, drawing on the precedent set in Chanchala's case. It stated that candidates passing through qualifying examinations held by a university form a class by themselves, and such classification has a reasonable nexus with the object of the rules. However, the Court found fault with the additional criterion of allocating seats based on the proportion of students registered for pre-degree and B.Sc. courses in the two universities, as it undermined the purpose of addressing Malabar's backwardness.

4. Implementation of a Uniform Entrance Examination:
The High Court suggested that a uniform entrance examination would be the best method for selection to secure uniformity of standards. The Supreme Court acknowledged this as a viable solution but noted the practical challenges and resistance from the student community. The Court recognized the need for gradual implementation and endorsed the State Government's long-term plan to unify curricula and examination standards across the two universities.

5. Temporary Solution for the Current Academic Year:
For the current academic year, the Supreme Court directed the State Government to admit 30 additional students from the Calicut University, maintaining the overall seat allocation of 166 for Calicut University and 317 for Kerala University. This temporary measure was aimed at avoiding disruption and ensuring fairness. The Court ordered the concerned universities and the Medical Council of India to accommodate the additional students and emphasized the need for swift action to implement the long-term unification of syllabi and examination standards by May 31, 1979.

Conclusion:
The Supreme Court allowed the appeal and the writ petition, directing the State Government to adjust the admissions for the current academic year and to work towards a unified examination system for future admissions. The Court's decision sought to balance the need for immediate relief with long-term solutions to ensure fairness and equality in the admission process.