Gauhati High Court Rejects Army Officer’s Daughter’s Claim to Nagaland’s Central Pool MBBS Seat

On October 28, 2025, a Division Bench of the Gauhati High Court (Chief Justice Ashutosh Kumar and Justice Arun Dev Choudhury) overturned a single judge’s ruling and upheld the Nagaland government’s 2021 notification excluding wards of defence personnel from the Central Pool MBBS quota allocated to the state. The case, The State of Nagaland and Others v. Vatsala Panghal and Another (WA/260/2025), clarifies the distinct policy objectives of separate quota categories.

Background

• Central Pool MBBS Seats: The Union Government allocates a portion of MBBS/BDS seats from the All-India pool to states deficient in medical education infrastructure. Nagaland receives 42 such seats annually.

• Central Guidelines (July 28, 2021): Eligible beneficiaries include children of Central/State/UT government employees on deputation or posted in the state with headquarters therein.

• Nagaland’s 2021 Notification: Explicitly excluded wards of defence personnel from these 42 seats, reserving them for domicile-based students to address local medical manpower shortages.

Petitioner’s Claim

Vatsala Panghal, daughter of an Indian Army Commanding Officer posted in Nagaland, qualified the NEET cut-off but was denied a Central Pool seat due to the 2021 notification. She argued:

• Her father’s posting in Nagaland made her eligible under the July 28 Central Guidelines.

• Exclusion was discriminatory and violated Article 14 (equality).

• She should be allowed dual eligibility — both under defence quota and Nagaland’s Central Pool quota.

A single judge had quashed the 2021 notification, ruling it contradictory to the Central Government guidelines.

Division Bench Reversal: Key Findings

The court upheld the state’s appeal and restored the 2021 notification, reasoning:

1. Defence Personnel Form a Separate Class

“When the Central Government… has chosen to treat defence personnel and their wards as a separate class with dedicated quota benefits, the exclusion of such a class from another pool cannot be termed discriminatory.”

2. Distinct Policy Objectives

   • Defence Quota: Recognizes national service and sacrifices of armed forces personnel.

   • Deficient State Quota (Nagaland): Compensates for lack of medical colleges and promotes local integration into mainstream healthcare.

“Both quotas operate under the same central pool, but each serves a separate beneficiary class. The policy of mutual exclusivity… bears a rational nexus to the scheme’s purpose.”

3. No Dual Benefit Allowed

   
   

   The petitioner failed to secure a seat under the defence quota due to falling short of its cut-off.

“She cannot claim a parallel advantage under another quota intended for a distinct beneficiary group.”

4. State’s Authority to Set Eligibility

   
   

   Nagaland has the power to apply its domicile-based reservation policy to Central Pool seats, as permitted by the guidelines.

“Central Pool seats are not a statutory entitlement but an executive measure for regional equity.”

5. No Violation of Article 14

   
   

   The classification between:

   • Ordinary residents / central govt employees posted in Nagaland, and

   • Wards of defence personnel (with independent quota)

     
     

     is based on intelligible differentia with a rational nexus to fair allocation.

Final Outcome

• Appeal allowed.

• 2021 notification upheld.

• Petitioner’s claim rejected.

The ruling reinforces that specialized quotas cannot be used interchangeably and protects the integrity of state-specific compensatory allocations.