CASE ANALYSIS – RAMNARESH @ RINKU KUSHWAH VS. STATE OF MADHYA PRADESH

INTRODUCTION

The case of Ramnaresh @ Rinku Kushwah v. State of Madhya Pradesh, decided by the Supreme Court on 20 August 2024, addressed a key issue in medical college admissions under the NEET-UG 2023 process.                                                                                                   Madhya Pradesh had introduced a Unreserved-Government School (UR-GS) quota meant to benefit meritorious students from government schools, regardless of caste.
However, the State wrongly split this horizontal quota into sub-categories like SC-GS, OBC-GS, etc., which led to less deserving students getting seats over those who had scored higher.                                                                                                                                                                 The affected students, though from reserved categories, had earned their place on pure merit, but were unfairly denied admission.
After the Madhya Pradesh High Court dismissed their petitions, they approached the Supreme Court.
The Supreme Court condemned the sub-categorisation, holding it to be unconstitutional and against the principle of merit.                                                                                                      It ruled that meritorious reserved-category students cannot be excluded from unreserved quotas if they qualify fairly.
The Court also directed that the students be accommodated in the next academic year (2024–25).
This judgment reaffirmed that equality and merit must go hand in hand in any reservation policy.

FACTS OF THE CASE 

1. In May 2023, Madhya Pradesh introduced a Government-School (GS) quota for NEET-UG admissions, divided into UR-GS, SC-GS, ST-GS, OBC-GS, and EWS-GS sub-quotas.
2.  The appellants (reserved-category candidates from government schools) scored higher than many admitted in the UR-GS category but were denied those seats; instead, many UR-GS seats (about 77) were transferred to the general pool. 
3. They filed writ petitions in the Madhya Pradesh High Courts (Indore and Gwalior benches), which dismissed them in December 2023 and January 2024, respectively. 
4.  The Supreme Court held on August 20, 2024, that such compartmentalisation violated settled law, quashed the High Court orders, and directed admission of the appellants in the 2024–25 session under the UR-GS quota. 

ISSUES OF THE CASE

• Whether the State of Madhya Pradesh was justified in sub-dividing the Unreserved–Government School (UR-GS) horizontal reservation into vertical caste-based categories like SC-GS, OBC-GS, and EWS-GS.
• Whether such compartmentalisation of a horizontal quota defeats the principle of merit and equality by preventing high-scoring reserved-category candidates from competing under the unreserved quota.
• Whether the action of the State violates constitutional principles under Articles 14, 15, and 16, which guarantee equality of opportunity in public education and employment.
• Whether the denial of seats to more meritorious candidates, based solely on their reserved status, amounts to an arbitrary and discriminatory classification.
• Whether the High Court erred in upholding the State’s compartmentalised reservation policy despite settled Supreme Court precedents protecting merit within horizontal reservations.

JUDGEMENT

1. The Court firmly ruled that if a student from a reserved category qualifies for a seat on merit under an unreserved quota (like UR-GS), they must be treated as a general merit candidate.
2. The Madhya Pradesh government’s move to split the UR-GS quota by caste (into SC-GS, OBC-GS, etc.) was declared unconstitutional and discriminatory.
3. The Court said this kind of compartmentalisation violates Articles 14 and 15 of the Constitution, which guarantee equality and non-discrimination in public education.
4. The bench cited important precedents like Indra Sawhney, Saurav Yadav, and Sadhana Singh Dangi, all of which upheld the priority of merit in horizontal reservations.
5. Even though the 2023–24 session had ended, the Court still provided relief. It ordered the State to admit the affected students in the 2024–25 academic year using the 7 seats wrongly left vacant.
6. The earlier High Court rulings that upheld the State’s method were quashed by the Supreme Court as legally unsustainable.
7. This ruling sent a strong message that states cannot misuse reservation policies in a way that defeats fairness and denies deserving students their rightful place.

REASONING

1. The Court stressed that merit cannot be ignored just because a candidate belongs to a reserved category. If a reserved-category student earns a seat based on merit, they should not be excluded from unreserved quotas like UR-GS.
2. The government wrongly split a horizontal quota (which cuts across all castes) into vertical caste-based compartments, which is not legally allowed. Horizontal reservations are meant to provide additional support without interfering with merit-based selection.
3. The Court held that this kind of artificial classification violates the right to equality by treating equally qualified candidates unequally—just because of their caste.
4. NEET-UG guidelines clearly mention that merit should be the key factor in admissions. The State’s policy contradicted the national rules, leading to injustice.
5. The Court referred to earlier rulings like Saurav Yadav v. State of Uttar Pradesh, where it was held that reserved-category candidates who qualify on merit must be placed in the general category.
6. Because of this flawed policy, 77 UR-GS seats remained vacant even though deserving students were available—this clearly showed that the system was broken and unfair.
7. The purpose of a horizontal reservation like UR-GS is to help students from disadvantaged backgrounds, not to discriminate within that group using caste again.
8. The Court reminded that a government policy cannot override constitutional principles or Supreme Court rulings. The intention may have been good, but the method was unlawful.

CONCLUSION

The Supreme Court concluded that fairness and merit must come first, even for students from reserved categories. It made it clear that the government cannot twist reservation rules in a way that ends up hurting deserving students.

The Court protected the rights of those who worked hard and earned their place, saying that opportunity should never be denied just because of caste. It corrected the injustice by ordering their admission in the next academic session, sending a strong message:         
Reservation should lift people up—not hold them back.

REFERENCES

1. newslaw.in+11scconline.com+11verdictum.in+11
2. freelaw.in+8casemine.com+8lawfoyer.in+8
3. indiankanoon.orgsooperkanoon.com
4. freelaw.in+10verdictum.in+10casemine.com+10

Written by Riya Tomar; an Intern under Legal Vidhiya.

Disclaimer: The materials provided herein are intended solely for informational purposes. Accessing or using the site or materials does not establish an attorney-client relationship. The information presented on this site is not to be construed as legal or professional advice, and it should not be relied upon for such purposes or used as a substitute for advice from a licensed attorney in your state. Additionally, the viewpoint presented by the author is personal.

Karan Chhetri

‘Social Media Head’ and ‘Case Analyst’ of Legal Vidhiya.