Summary and Analysis of The State of Telangana & Ors Etc vs Kalluri Naga Narasimha Abhiram & Ors Etc 2025 INSC 1058

1. Heading of the Judgment

Supreme Court of India – Civil Appellate Jurisdiction
Civil Appeal Nos. ______ of 2025 (Arising from SLP (C) Nos. 21536–21588 of 2024)
Appellants: The State of Telangana & Others
Respondents: Kalluri Naga Narasimha Abhiram & Others
Date of Judgment: September 1, 2025
Judges: Hon’ble Chief Justice B.R. Gavai and Hon’ble Mr. Justice K. Vinod Chandran

Citation: The State of Telangana & Ors. Etc. v. Kalluri Naga Narasimha Abhiram & Ors. Etc., 2025 INSC 1058 (Supreme Court of India, September 1, 2025).

2. Relevant Laws and Sections

• Constitution of India:
  Article 371D: Special provisions for Andhra Pradesh and Telangana regarding equitable opportunities in education and employment
  Article 14: Right to Equality
  Articles 245–246: Legislative powers of Parliament and State Legislatures

• Andhra Pradesh Reorganisation Act, 2014: Continuation of benefits under Article 371D for ten years in Telangana and Andhra Pradesh

• Andhra Pradesh Educational Institutions (Regulations of Admissions) Order, 1974 (Presidential Order): Defines "local candidate" for reservation in admissions

• Telangana Medical & Dental Colleges Admission Rules, 2017 (Amended in 2024): Rules for admission to MBBS/BDS courses, including "Competent Authority Quota"

3. Basic Judgment Details

The Supreme Court allowed the appeals filed by the State of Telangana and set aside the judgments of the High Court of Telangana. The Court upheld the validity of the definition of "local candidate" under the Presidential Order and the State Rules, which require four consecutive years of study or residence in Telangana for eligibility under the "Competent Authority Quota." The High Court’s expansion of the definition was held to be unconstitutional.

4. Explanation of the Judgment

Background

The case involved challenges to the definition of "local candidate" in the Telangana Medical & Dental Colleges Admission Rules, 2017 (amended in 2024). The Rules reserved 85% of MBBS/BDS seats for "local candidates" who:

• Studied in Telangana for four consecutive academic years ending with the qualifying examination, or

• Resided in Telangana during those four years (if not studying) and appeared for the qualifying examination in Telangana.

Students who did not meet these criteria (e.g., those who studied outside Telangana due to parents’ employment) challenged the Rules as arbitrary and violative of Article 14. The High Court expanded the definition to include students with a "residence certificate" from Telangana.

Key Issues Before the Supreme Court

1. Whether the Rules of 2017 (and amended Rules of 2024) were valid under Article 371D and the Presidential Order?

2. Whether the High Court could expand the definition of "local candidate" under Article 226?

3. Whether the Rules were arbitrary and violated Article 14?

Supreme Court’s Analysis & Directions

A. Validity of the Rules Under Article 371D and Presidential Order

• The Court held that the Rules were validly framed under the Presidential Order of 1974 (issued under Article 371D) and the Telangana Educational Institutions (Regulation of Admission and Prohibition of Capitation Fee) Act, 1983.

• The Rules aimed to provide equitable opportunities to students who had a genuine connection with Telangana and were likely to serve the State after completing their education.

• The definition of "local candidate" was based on objective criteria (study/residence) rather than subjective claims of nativity.

B. High Court’s Expansion of Definition Unconstitutional

• The High Court’s expansion of the definition to include students with a "residence certificate" was set aside.

• The Supreme Court held that the High Court overstepped its jurisdiction under Article 226 by rewriting the Rules, which were based on a valid Presidential Order and legislative policy.

• The Court emphasized that policy decisions regarding reservations should be made by the legislature/executive, not the judiciary.

C. Rules Not Arbitrary or Violative of Article 14

• The Court cited precedents (D.P. Joshi v. State of M.P., Pradeep Jain v. Union of India, Anand Madaan v. State of Haryana, etc.) to uphold the constitutionality of residence-based reservations.

• Such reservations are valid to:
  Ensure equitable opportunities for local students.
  Address regional backwardness and shortage of medical professionals.
  Encourage students to serve in their home States after qualification.

• The Rules were not exclusionary, as students could still compete for the 15% All-India quota or seek admission in other States.

D. Mitigation for Certain Categories

• The State proposed a proviso to Rule 3 to accommodate students who studied outside Telangana due to:
  Parents’ employment in Telangana State Government (serving outside Telangana).
  Parents in All-India Services (IAS/IPS/IFS) from Telangana cadre serving outside.
  Defence/CAPF personnel with declared hometown in Telangana.
  Employees of Telangana State Corporations/PSUs transferred outside.

• Such students must provide a certificate of employment from competent authorities.

• The Court approved this proviso and directed the State to incorporate it into the Rules.

E. Protection of Previous Admissions

• Admissions made in the previous academic year (based on the High Court’s interim order) were protected and not disturbed.

Conclusion

The Supreme Court upheld the validity of the Rules defining "local candidate" and set aside the High Court’s judgments. The Rules were found to be constitutional and in line with the Presidential Order under Article 371D. The Court approved the State’s proposal to include a proviso for students affected by parents’ employment transfers, ensuring a balance between state interests and individual hardships.