Sports Quota Admissions To MBBS/BDS: Supreme Court Quashes Midstream Policy Change In Punjab 2024 Session

The Supreme Court has set aside the midstream expansion of the zone of consideration for sports quota admissions to MBBS and BDS courses in Punjab, holding that altering admission criteria after the process has commenced violates settled principles of fairness, transparency and non-arbitrariness under Article 14 of the Constitution.

A Bench of Justice Sanjay Kumar and Justice Alok Aradhe allowed a batch of civil appeals arising from orders of the Punjab and Haryana High Court, which had dismissed challenges to the inclusion of sports achievements from Classes IX and X, in addition to Classes XI and XII, for admissions during the 2024 session.

Background 

The appeals concerned admissions to MBBS and BDS courses under the 1 percent sports quota in Punjab for the 2024 session. The Prospectus initially issued by Baba Farid University of Health Sciences on 09 August 2024 clearly stated that credit would be given only for sports achievements during Classes XI and XII.

However, on the last date for submission of applications, the University issued an email at 6.07 pm on 16 August 2024, asking candidates to submit sports achievements of any class or year. This was followed by an addendum and the preparation of a sports merit list that took into account achievements from Classes IX and X as well. On that basis, Kudrat Kashyap and Mansirat Kaur were ranked higher than appellants Divjot Sekhon and Shubhkarman Singh.

Supreme Court's Findings

The Court held that the admission process was vitiated by arbitrariness and lack of transparency. It reiterated the settled principle that the “rules of the game cannot be changed once the game has begun”, observing that this doctrine applies equally to admission processes as it does to recruitment.

The Bench noted that while the State's Corrigendum dated 01 August 2023 had expanded the zone of consideration to include Classes IX and X, it was expressly limited to the 2023 session due to Covid-19. There was no justification to perpetuate that exception in 2024.

Crucially, the Court found that the policy change was triggered by a representation from Ramesh Kumar Kashyap, a roller skating coach, who failed to disclose that his daughter, Kudrat Kashyap, would directly benefit from the change. The files placed before the Court showed that his representation influenced the authorities and ultimately resulted in the expanded zone of consideration.

The Court held that this lack of disclosure alone was sufficient to vitiate the modification, observing that the foundation of the policy change stood tainted.

Arbitrariness And Double Standards

The Bench also highlighted glaring inconsistencies. During the same 2024 session, sports achievements for several other medical and allied courses were assessed only on the basis of Classes XI and XII. Even for postgraduate medical and dental courses, the prospectus limited consideration to achievements during MBBS and BDS.

The Court noted that the Sports Policy, 2023 did not specify the academic years to be considered for sports achievements and, in fact, excluded sub-junior tournaments. Yet, the University's email sought achievements from any class or year, creating scope for arbitrariness and favouritism.

Relying on earlier decisions, the Court emphasised that even policy decisions must satisfy the test of reasonableness under Article 14. It observed that leaving admission norms “elastic” and undefined at the outset enables arbitrariness and nepotism to enter “through the backdoor”.

The Bench held that the State cannot justify the 2024 change by citing the 2023 Covid-related exception and that any modification to admission criteria must be fully defined before the process begins.

Relief Granted For 2024 Admissions

While holding the policy change illegal, the Court limited the relief to the appellants before it, to avoid unsettling completed admissions. It directed that:

Divjot Sekhon and Shubhkarman Singh be accommodated in the government medical college seats allotted to Kudrat Kashyap and Mansirat Kaur.

Kudrat Kashyap and Mansirat Kaur be shifted to the private college seats earlier occupied by the appellants.

The studies already undertaken and fees paid by all candidates would remain unaffected.

On Admissions For 2025 Session

The Court noted that the same flawed policy was continued for the 2025 session. However, since admissions were already completed and affected candidates were not before the Court, it declined to grant immediate relief. The appellants for the 2025 session were given liberty to approach the High Court afresh by impleading all necessary parties.

Allowing the appeals, the Supreme Court quashed the midstream modification of the sports quota policy for MBBS and BDS admissions, underscoring that transparency, consistency and absence of arbitrariness are non-negotiable in admission processes for highly sought-after courses. The Court left it open to the State of Punjab to frame a reasoned and comprehensive policy in advance for future sessions, uninfluenced by extraneous representations.

Appearances: For petitioners - In SLP(C) No. 23112/2024, Ms. Misha Rohatgi, AOR, appeared along with Mr. Suneet Pal Singh Aulakh, Mr. Nakul Mohta, Mr. Ayush Kashyap and Mr. Amulya Upadhyay, Advocates; in SLP(C) No. 28046/2024, Ms. Jyoti Mendiratta, AOR, appeared; and in SLP(C) No. 20137/2025, Mr. B.K. Satija, AOR, appeared,

For the respondents :  The State of Punjab was represented by Mr. Siddhant Sharma, AOR, and Baba Farid University of Health Sciences by Mr. Vikram Choudhary, Advocate, with Mr. G.K. Bansal and Mr. Anuj Tyagi, AORs, and Mr. Nitin Kaushal, Mr. Manoj Pandey and Ms. Shreelekha Vyas, Advocates, along with Ms. Tanya Swarup, AOR.

Case : Divjot Sekhon v. State of Punjab

Citation : 2026 LiveLaw (SC) 12

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