In Tanvi Behl & Shrey Goel v. The State of Uttar Pradesh & Others, the Supreme Court reaffirmed that under Article 5 of the Indian Constitution, all Indians have a single domicile—the “Domicile of India.” The concept of state or provincial domicile is not recognized in Indian law. This ruling was delivered while examining the constitutionality of domicile-based reservations in postgraduate (PG) medical admissions. The Court clarified that while state governments often misuse the term “domicile” to mean “permanent residence,” legally, domicile refers to a person’s permanent home with the intent to reside there indefinitely. It further distinguished that while domicile-based reservations can be allowed to a limited extent for undergraduate (MBBS) medical admissions, they cannot be extended to PG medical courses. Emphasizing the importance of specialist doctors, the Court held that domicile-based reservations in PG medical admissions violate Article 14 of the Constitution. Consequently, it ruled that state quota seats, apart from a reasonable number of institution-based reservations, must be filled strictly on merit based on the All-India examination. This decision reinforces the principle of merit-based selection in higher medical education while ensuring equal opportunities for all candidates across the country.
