Gauhati High Court rules against defence ward in Nagaland MBBS seat case

DIMAPUR — The Gauhati High Court has set aside a Kohima Bench ruling that had directed the Nagaland government to allot an MBBS seat under the central pool quota to Vatsala Panghal, daughter of a serving Army officer posted in Kohima.

A Division Bench comprising Chief Justice Ashutosh Kumar and Justice Arun Dev Choudhury on October 23 allowed the state government’s appeal against the single judge’s August 14 order, holding that wards of defence personnel are not eligible to claim seats under the quota meant for states with deficient medical infrastructure.

The court observed that the “defence quota and the deficient state quota are mutually independent and non-interchangeable sub-schemes under the overall central pool”, and that a candidate who falls under one cannot simultaneously claim benefits under the other.

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The bench concluded that “for the purpose of availing such benefit, a defence personnel cannot be treated as a central government employee” and that the petitioner, being a ward of an Army officer, was therefore not eligible for the Nagaland quota seat.

Dual entitlement ruled out

Panghal, daughter of the Commanding Officer of 1 Nagaland Battalion NCC, had earlier secured 455 marks in NEET and challenged the omission of her name from the state’s merit list despite scoring above the cut-off. She argued that under the Union Health Ministry’s July 28, 2025, guidelines, wards of central government employees posted in a state are to be treated at par with local residents.

The single judge, Justice Mridul Kumar Kalita, had agreed with her contention and quashed the state’s 2021 notification that restricted eligibility to candidates whose parents had resided or been posted in Nagaland for at least three years. He held that the rule violated the Centre’s guidelines and Article 14 of the Constitution, and ordered the directorate of Technical Education to allot a central pool seat to Panghal.

However, in its appeal, the state government argued that the petitioner could not claim dual entitlement—under both the “deficient state” quota for Nagaland and the “defence personnel” quota—since each was meant for distinct beneficiary groups.

Upholding the state’s position, the Division Bench ruled that the law “disfavours dual benefit under two different welfare schemes emanating from the same source.” It added that once a candidate’s category as a ward of defence personnel is established, she must seek admission under that quota and not under another created for a different purpose.

Quotas serve distinct objectives

The court emphasised that the central pool is administered by the Ministry of Health and Family Welfare, which distributes seats among various beneficiary categories each year. The “deficient state” quota exists to strengthen the medical human resource base in states lacking adequate medical colleges, while the defence quota recognises and rewards national service by defence personnel.

“The policy of mutual exclusivity between the defence pool and the deficient pool thus bears a rational nexus to the scheme’s purpose and cannot be termed arbitrary,” the order stated.

Rejecting the single judge’s finding that the 2021 state notification was arbitrary, the bench observed that it did not violate the July 2025 guidelines since the two quotas served distinct policy objectives. The court held that the petitioner’s exclusion did not amount to discrimination under Article 14 of the Constitution.

For 2025–26, Nagaland was allotted 152 MBBS seats, including 42 from the central pool for states with inadequate medical infrastructure. The Ministry of Health and Family Welfare also earmarked a separate 45 seats (42 MBBS and 3 BDS) under the central pool for wards of defence personnel.

The case had drawn significant public attention, with the Naga Students’ Federation (NSF) and the Nagaland Medical Students’ Association (NMSA) objecting to Panghal’s candidature. Both groups argued that she was not an indigenous inhabitant of Nagaland and that allowing such claims would deprive indigenous Naga students of opportunities meant for them.