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2026 DAILYLAW 16781 (CHH)

DR. SAMRIDDHI DUBEY v. THE STATE OF CHHATTISGARH

WPC/366/2026 · 2026-01-29

Shri Ravindra Kumar Agrawal

body2026

Judgment text

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1 2026:CGHC:5182-DB NAFR HIGH COURT OF CHHATTISGARH AT BILASPUR WPC No. 366 of 2026 Dr. Samriddhi Dubey D/o Shri Sandeep Dubey Aged About 25 Years R/o Om Zone Colony, Shubham Vihar, Mangala, Bilaspur, District Bilaspur (Chhattisgarh) ... Petitioner versus 1 - The State of Chhattisgarh Through The Secretary, Department of Public Health And Family Welfary, Mantralaya, Mahanadi Bhawan, Nava Raipur, Atal Nagar, District Raipur, Chhattisgarh, 492002 2 - The Director Medical Education, Directorate of Medical Education, Swasthya Bhawan, Sector 19, North Block, Atal Nagar, Nava Raipur, Chhattisgarh, 492002 3 - The Commissioner Medical Education Commissionerate of Medical Education, Swasthya Bhawan, 2th Floor, Sector 19, North Block, Atal Nagar, Nava Raipur, Chhattisgarh, 492002 4 - The National Medical Commission Ministry Of Health And Family Welfare Through Its Director, Pocket- 14, Sector-8, Dwarka, Phase- 1, New Delhi- 110077 ... Respondents (Cause-title taken from Case Information System) For Petitioner : Mr. Rajeev Shrivastava, learned Senior Advocate assisted by Mr. Sandeep Dubey and Mr. Kaif Ali, Advocate For Respondents No.1 to 3 : Mr. Shashank Thakur, Additional Advocate General For Respondent No.4 : Mr. Dhiraj Kumar Wankhede, Advocate ANURADHA TIWARI Digitally signed by ANURADHA TIWARI Date: 2026.01.31 10:36:12 +0530 2 Hon'ble Shri Ramesh Sinha, Chief Justice Hon'ble Shri Ravindra Kumar Agrawal , Judge Order on Board Per Ramesh Sinha, Chief Justice 30 .01.2026 1. Heard Mr. Rajeev Shrivastava, learned Senior Counsel assisted by Mr. Sandeep Dubey and Mr. Kaif Ali, learned counsel for the petitioner as well as Mr. Shashnak Thakur, learned Additional Advocate General, appearing for the State/respondents No.1 to 3 and Mr. Dhiraj Kumar Wankhede, learned counsel appearing for respondent No.4. 2. By way of this writ petition, the petitioner has prayed for following relief(s):- “10.1 That, the Hon'ble Court may kindly be pleased to call for the record in WPC/5937/2025 ~Dr. Samriddhi Dubey Vs State of Chhattisgarh as well as MCC/40/2026~The State of Chhattisgarh and other vs. Dr. Samriddhi Dubey. 10.2 That, the Hon'ble Court may kindly be pleased to issue direction/directions, writ/writs in the nature of certiorari and declare the amendment dated 22.01.2026 in Rule 11 of the Chhattisgarh Medical Post Graduate Admission Rules, 2025 (Annexure-P/1) ultra virus / unconstitutional being voilative of the Article 14 of the Constitution of India in the interest of Justice. 10.3 That, the Hon'ble Court may kindly be 3 pleased to issue direction/directions, writ/writs in the nature of certiorari and quash / set-aside the notification dated 22.01.2026 (Annexure- P/2) in the interest of Justice. 10.4 That, the Hon'ble Court may kindly be pleased to issue direction/directions, writ/writs in the nature of certiorari and direct the respondents not to discriminate between the candidates belonging to categories mentioned in the amendment Rules, 2025 dated 22.01.2026. 10.5 That, this Hon'ble Court may kindly be pleased to grant any other relief(s), which is deemed fit and proper in the aforesaid facts and circumstances of the case including claim in subject dispute.” 3. Learned Senior Counsel for the petitioner submits that the entire exercise undertaken by the State Government by amending Rule 11 of the Chhattisgarh Medical Post Graduate Admission Rules, 2025 on 22.01.2026 is ex facie arbitrary, illegal and vitiated by mala fides, inasmuch as it seeks to virtually nullify and overreach the binding judgment dated 20.11.2025 passed by the Division Bench of this Court in WPC/5937/2025 (Dr. Samriddhi Dubey Vs. State of Chhattisgarh and others), 2025 SCC OnLine Chh 10927, as well as the clarification order dated 16.01.2026 passed in MCC/40/2026. It is submitted that the earlier amendment dated 01.12.2025 was admittedly brought in compliance of the said judgment and was also in consonance with the law laid down by the Hon’ble Supreme Court in Dr. Tanvi Behl Vs. Shrey Goel 4 and others (Civil Appeal No. 9289 of 2019). However, by merely changing certain words and expressions through the subsequent amendment dated 22.01.2026, the State has attempted to resurrect the very scheme of total institutional reservation which had already been declared unconstitutional, thereby rendering the amendment contemptuous in nature. 4. Learned Senior Counsel further submits that once the State itself had acted upon the amended Rules dated 01.12.2025, conducted the first and second rounds of counselling, allotted seats and granted admissions to eligible candidates including the present petitioner, the State was estopped in law from altering the rules of the game midstream. It is a settled proposition of law that the conditions of selection and admission cannot be changed after the commencement of the selection process, much less after its substantial completion. The cancellation of all admissions made pursuant to the first and second rounds of counselling, solely on the basis of a subsequent amendment dated 22.01.2026, is therefore violative of Articles 14 and 16 of the Constitution of India and hits at the very root of fairness, certainty and transparency in public admissions. 5. Learned Senior Counsel also submits that the impugned amendment dated 22.01.2026, under the guise of creating an “open category”, in effect reintroduces reservation norms even within the so-called open seats, thereby resulting in 100% 5 institutional and category-based reservation. Such a device is nothing but an indirect method of doing what could not be done directly and is squarely impermissible in view of the authoritative pronouncement of the Hon’ble Supreme Court in Dr. Tanvi Behl (supra), wherein it has been categorically held that institutional preference cannot eclipse merit and that a portion of seats must remain truly open and available to all eligible candidates on the basis of inter se merit alone. The learned Senior Counsel submits that the amended Rule 11(b), as brought into force on 22.01.2026, clearly violates the said constitutional mandate and judicial dictum. 6. Learned Senior Counsel lastly submits that the action of the State Government is also contrary to the repeated directions issued by the National Medical Commission mandating strict adherence to the admission timelines fixed by the Hon’ble Supreme Court for postgraduate medical courses. The State having consciously framed the amendment dated 01.12.2025, defended the same on affidavit before this Court, and allowed admissions to be completed thereunder, could not have retrospectively unsettled vested rights of students by introducing a subsequent amendment with only prospective effect. Such arbitrary cancellation of admissions not only causes irreparable prejudice to meritorious candidates but also leads to chaos in the admission process, which has been consistently deprecated by constitutional courts. On this ground alone, the impugned amendment dated 6 22.01.2026 deserves to be quashed and all admissions made pursuant to the valid amendment dated 01.12.2025 deserve to be protected. 7. On the other hand, learned Additional Advocate General appearing for the State vehemently opposes the submissions advanced by learned Senior Counsel for the petitioner and submits that this Court has already considered, examined and conclusively adjudicated the very same issue in WPC No. 367 of 2026 (Anushka Yadav v. State of Chhattisgarh and others) vide judgment dated 27.01.2026. 8. It is submitted that in the said judgment, this Court, after taking into consideration the amendment of Rule 11 of the Chhattisgarh Medical Post Graduate Admission Rules, 2025, the judgment of the Hon’ble Supreme Court in Dr. Tanvi Behl (supra), as well as the clarification order passed in MCC No. 40 of 2026, has categorically held that no candidate can claim any vested or indefeasible right on the basis of provisional allotment or admission, once the statutory rules governing admission stand amended in accordance with law. It is further submitted that the cancellation of earlier rounds of counselling and consequential admissions was necessitated to bring the admission process in strict conformity with constitutional principles and binding judicial pronouncements, and such action does not suffer from arbitrariness or illegality. 7 9. Learned Additional Advocate General thus submits that the present writ petition is squarely covered by the judgment rendered in Anushka Yadav (supra) and deserves dismissal on the ground of parity, judicial discipline and to avoid inconsistent decisions on identical issues. 10. Learned counsel appearing for respondent No. 4 adopts the submissions advanced by the learned Additional Advocate General appearing for the State and supports the impugned action of the respondent–State. 11. After considering the submissions advanced by the learned counsel for the parties and upon perusal of the material available on record, this Court, vide judgment dated 27.01.2026, dismissed WPC No. 367 of 2026 in the following terms:– “15. The Chhattisgarh Government has framed the Chhattisgarh Medical Post Graduate Admission Rules, 2025, which is applicable w.e.f. 06.11.2025 provided the institutional preference to the candidates and the candidates, who are given preference, may not necessarily be domicile to the State of Chhattisgarh. Rule 11 of the said Rules of 2025 is necessary to notice here:- “11- izos’k esa ojh;rk%& ¼d½ jkT; dksVs esa miyC/k lhVksa ij loZizFke mu vH;fFkZ;ksa dks izos’k fn;k tk,xk] ftUgksaus ;k rks ia- nhun;ky mik/;k; Le`fr LokLF; foKku ,oa vk;q"k fo’ofo|ky;] NRrhlx< ls lac) fpfdRlk egkfo|ky; ls ,echch,l fMxzh izkIr dh gks vFkok tks lsokjr vH;FkhZ gksA 8 ¼[k½ mijksDr mi&fu;e ¼d½ esa mfYyf[kr lHkh ik= vH;fFkZ;ksa dks izos’k fn;s tkus ds mijkUr ;fn lhVsas fjDr jg tkrh gSa] rks bu fjDr lhVksa ij] ,sls”vH;fFkZ;ksa dks izos’k fn;k tk;sxk] ftUgksaus fu;e 11¼d½ esa mYysf[kr ds vfrfjDr fdlh vU; fpfdRlk egkfo|ky; ls ,echch,l fMxzh izkIr dh gksA”” 16. Earlier, one Dr. Samriddhi Dubey had filed a WPC No. 5937 of 2025 (Dr. Samriddhi Dubey v. State of Chhattisgarh and others) before coordinate Bench of this Court, which was decided on 20.11.2025 and in para 21 of the order, it has been decided that:- “21. In view of the proposition of law as laid down by the Apex Court in Dr. Tanvi Behl (supra), Rule 11(a) and (b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025 are quashed being ultra vires and violative of Article 14 of the Constitution of India and the State shall not discriminate between the candidates belonging to the categories mentioned in Rule 11(a) and (b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025.” 17. Subsequent to that an application for clarification of the directions contained in paragraph 21 of the order dated 20.11.2025 passed in WPC No. 5937 of 2025 was filed by the State, which was registered as MCC No. 40 of 2026 (State of Chhattisgarh and others v. Dr. Samriddhi Dubey and others) and vide order dated 16.01.2026, the MCC was disposed of clarifying the followings:- “14. According to the learned counsel for the applicant/State, the Government of Chhattisgarh, Medical Education Department, has issued a notification dated 01.12.2025 by substituting Rule 11(d) and ([k) and substituting it by Rule (d), ([k), 9 (x) (?k) of the Rules of 2025. Though the same is not the subject matter of this petition, however, for better understanding of the facts, we deem it appropriate to take note of the same, which reads as under: “11- izos’k gsrq lhVksa dk laLFkkxr vkj{k.k %& 'kkldh; ,oa futh fpfdRlk dh dqy miyC/k lhVksa dks nks oxksZa esa foHkkftr fd;k tkrk gSaA laLFkkxr vkj{k.k gsrq 50 izfr’kr lhVsa] rFkk vksiu esfjV gsrq 50 izfr’kr lhVsaA ¼d½ laLFkkxr vkj{k.k & 50 izfr’kr lhVsa 'kkldh; ,oa futh fpfdRlk egkfo+|ky;ksa dh dqy lhVksaa mu vH;fFkZ;ksa ds fy, vkjf{kr jgsxk ftUgksaus NRrhlx< jkT; esa fLFkr ,u,elh }kjk ekU;rk izkIr fpfdRlk egkfo|ky;ksa ls ,echch,l mRrh.kZ fd;k gS vFkok tks lsokjr vH;FkhZ gSA bu lhVksa ij izos’k dsoy laLFkkxr vkj{k.k ds ik= vH;fFkZ;ksa ds e/; esfjV ds vk/kkj ij fn;k tk,xkA ¼[k½ xSj laLFkkxr vkj{k.k & 50 izfr’kr lhVsa xSj laLFkkxr vkj{k.k 'ks"k 50 izfr’kr lhVsa vksiu dSVsxjh ekuh tk,axhA bu lhVksa ij izos’k lHkh ik= vH;fFkZ;ksa gsrq jkT;&Lrjh; esfjV lwph ds vk/kkj ij fd;k tk,xkA vksiu lhVksa ij fdlh izdkj dh laLFkkxr vkj{k.k ykxw ugha gksxhA ¼x½ mijksDr nksuksa Js.kh;ksa es jkT; esa izpfyr vkj{k.k fu;e 6 ds rgr ykxw gksxkA ¼?k½ ;fn laLFkkxr vkj{k.k ds varxrZ fu/kkZfjr lhVksa ij ik= vH;FkhZ miyC/k ugha gksrs gSa] rks ekWi&vi jkm.M dh vkoaVu izfdz;k ds le; mu fjDr lhVksa dk varj.k (conversion) djrs gq, mUgsa lkekU; (vksiu) Js.kh esa dj fn;k tk,xkA” 15. The Hon’ble Apex Court, in Tanvi Behl (supra) has observed that domicile based reservation in PG Medical course is bad but the Apex Court has also clearly stated that a reasonable number of institution based reservation is permissible. Further, a miscellaneous application being MA No. 512/2025 in CA No. 9289/2019 was filed before the Apex Court, wherein the Hon’ble Apex Court vide order dated 24.03.2025, in the first paragraph has observed that the residence based 10 reservations were not permissible for postgraduate seats in medical colleges and that only reservation to a limited extent is permissible, for institutional preference alone, meaning thereby that institutional preference is permitted to a certain extent. 16 In view of the above, the contents of paragraph 21 of the order dated 20.11.2025 passed in WPC No. 5937/2025, “and the State shall not discriminate between the candidates belonging to the categories mentioned in Rule 11(a) and (b) of the Chhattisgarh Medical Post Graduate Admission Rules, 2025”, stands deleted and the State shall act in accordance with the ratio laid down by the Apex Court in Tanvi Behl (supra).” 18. In the case of “Dr. Tanvi Behl” (supra), the Hon’ble Supreme Court has held that:- “31. We are all domiciled in the territory of India. We are all residents of India. Our common bond as citizens and residents of one country gives us the right not only to choose our residence anywhere in India, but also gives us the right to carry on trade & business or a profession anywhere in India. It also gives us the right to seek admission in educational institutions across India. The benefit of ‘reservation’ in educational institutions including medical colleges to those who reside in a particular State can be given to a certain degree only in MBBS courses, for which we have assigned reasons in the preceding paragraphs. But considering the importance of specialists doctors’ in PG Medical Course, reservation at the higher level on the basis of ‘residence’ would be violative of Article 14 of the Constitution of India. This has been explained with pronounced clarity both in Jagadish Saran and Pradeep Jain. If such a reservation is permitted then it would be an invasion on the fundamental rights of several students, who are being treated unequally simply for the reasons 11 that they belong to a different State in the Union! This would be a violation of the equality clause in Article 14 of the Constitution and would amount to a denial of equality before the law. 32. The law laid down in Jagadish Saran and Pradeep Jain has been followed by this Court in a number of decisions including the Constitution Bench decision in Saurabh Chaudri. We may also refer here judgments such as Magan Mehrotra and Ors. v. Union of India (UOI) and Ors. (2003) 11 SCC 186, Nikhil Himthani vs. State of Uttarakhand and Others (2013) 10 SCC 237, Vishal Goyal and Others v. State of Karnataka and Others (2014) 11 SCC 456 and Neil Aurelio Nunes (OBC Reservation) and Others v. Union of India and Others (2022) 4 SCC 1, which have all followed Pradeep Jain. Thus, residence-based reservations are not permissible in PG medical courses. 33. Having made the above determination that residence-based reservation is impermissible in PG Medical courses, the State quota seats, apart from a reasonable number of institution-based reservations, have to be filled strictly on the basis of merit in the All- India examination. Thus, out of 64 seats which were to be filled by the State in its quota 32 could have been filled on the basis of institutional preference, and these are valid. But the other 32 seats earmarked as U.T. Chandigarh pool were wrongly filled on the basis of residence, and we uphold the findings of the High Court on this crucial aspect.” 19. When the coordinate Bench of this Court has already clarified in paragraph 21 of the order dated 20.11.2025, passed in WPC No. 5937 of 2025 that, the State shall not discriminate between the candidates belonging to the categories mentioned in Rule 11 (a) and (b) of the Chhattisgarh Medical Post Graduate Admission 12 Rules, 2025, the petitioner cannot claim any benefit, even if she was provided the provisional admission in the PG Medical Course and she paid the requisite fee against the allotted seat. 20. 20. On 22.01.2026, the State Government vide its notification amended the Chhattisgarh Medical Post Graduate Admission Rules, 2025 and the Rule 11 has been amended, which is given as below:- अधिसूचना *******्ቅमांक RULE-801/205/2025-MED. छ्ቈीसगढ़ धिचकिकत्सा महाकि्ቕालय के स्नातको्ቈर पा्቏्ቅम में ्ቚदेश अधिकिनयम 2002 ( 28 सन् 2002) की ारा-3 सहप fBr ारा 4 ्ቛारा ्ቚद्ቈ शकि(यों को ्ቚयोग में लाते हुए राज्य राज्य सरकार ,rn}kjk छ्ቈीसगढ़ धिचकिकत्सा स्नातको्ቈर ्ቚेश किनयम, 2025 में किनम्नलिललि/त संशोन करते है. अቕኋा2त- संशोन उ( किनयमों में- *******किनयम-11 के स्ቕኋान पर किनम्नलिललि/त किनयम ्ቚधितस्ቕኋाकिपत किकया जाये. अቕኋा2त्- 11. ्ቚेश हेतु सीटों का किभाजन (d) शासकीय धिचकिकत्सा महाकि्ቕालयों की सीटों में अलि/ल भारतीय कोटे हेतु समቚኌपत की गई 50 ्ቚधितशत सीटों के उपरांत शेष उपलब् 50 ्ቚधितशत राज्य कोटे की सीटों पर े पंजीकृ त अभ्यቕኋ= जिजन्होंने एम.बी.बी. एस. पा्቏्ቅम छ्ቈीसगढ़ राज्य में ቝኌस्ቕኋत रा्ቖ्रीय आयुቚኌ्ሺान आयोग ्ቛारा मान्यता ्ቚा्቎ धिचकिकत्सा महाकि्ቕालयों से उ्ቈी्ቓ2 किकया है अቕኋया जो छ्ቈीसगढ़ राज्य के सेारत अभ्यቕኋ= हैं. ्ቚेश हेतु पा्ቔ होंगे। (/) किनजी धिचकिकत्सा महाकि्ቕालयों की सीटों में कु ल सीटों के 50 ्ቚधितशत सीटों पर े पंजीकृ त अभ्यቕኋ=, जिजन्होंने एम.बी. बी एस पा्቏्ቅम छ्ቈीसगढ़ राज्य में ቝኌस्ቕኋत रा्ቖ्रीय आयुቚኌ्ሺान आयोग ्ቛारा मान्यता ्ቚा्቎ धिचकिकत्सा महाकि्ቕालयों से उ्ቈी्ቓ2 किकया है अቕኋा जो छ्ቈीसगढ़ राज्य के सेारत अभ्यቕኋ= है, ्ቚेश हेतु पा्ቔ होंगे। 13 *******शेष उपलब् 50 ्ቚधितशत सीटों को ्ቚाीण्यता के आार पर ओपन सीटों की Hkkafr आंकिटत किकया जाएगा। इस ्ቚयोजन हेतु ऐसे अभ्यቕኋ= जिजन्होंने एम.बी.बी.एस. पा्቏्ቅम छ्ቈीसगढ़ राज्य में ቝኌस्ቕኋत रा्ቖ्रीय आयुቚኌ्ሺान आयोग ्ቛारा मान्यता ्ቚा्቎ धिचकिकत्सा महाकि्ቕालयों से उ्ቈी्ቓ2 नहीं किकया है (गैर संस्ቕኋागत अभ्यቕኋ=), पा्ቔ होंगे। (ग) किनजी धिचकिकत्सा महा कि्ቕालयों की 50 ्ቚधितशत ओपन सीटों पर भी राज्य में ्ቚचलिलत आर्ቌ्ቓ किनयम-6 लागू होगा। (?k) यकिद शासकीय धिचकिकत्सा महाकि्ቕालय की सीटों के किरु्ቍ पा्ቔ अभ्यቕኋ= उपलब् नहीं होते हैं एं सीटें रिर( रह जाती है. rks काउंजिसिሴलग की तृतीय चर्ቓ की आंटन ्ቚकि्ቅया के समय उन रिर( सीटों को रूपांतरिरत (Conversion) करते हुए उन्हें गैर संस्ቕኋागत अभ्यቕኌቕኋयों को आंकिटत किकया जा सके गा। 21. Pursuant to the notification dated 22.01.2026, considering that there may be change of entire reservation roster/seat matrix and the allotment may also be changed, an order has been issued by the respondent No.3 on 22.01.2026 and cancelled the first and second phase of counselling and also cancelled the allotment of the seats vide its notice dated 22.01.2026 (Annexure P/1) and on 23.01.2026, an explanation has been published by the respondent No.3 to clarify the allotment of seats under the institutional and non-institutional quota. The said clarification is also necessary to notice here:- “ छ्ቈीसगढ़ राजप्ቔ (असाार्ቓ) ्ቅमांक 40. अधिसूचना ्ቅमांक RULE-801/205/2025-MED, ना रायपुर अटल नगर, किदनांक 22 जनरी 2026 ्ቛारा धिचकिकत्सा स्नातको्ቈर (एम.डी./एम.एस.) पा्቏्ቅम, ्ቚेश ष2 2025 के किनयमों में किकए गए संशोन के संबं में यह स्प्ቖ किकया जाता है किक उ( अधिसूचना में उजिXलि/त '50 ्ቚधितशत सीटों पर ओपन कै टेगरी (Open Category) के आार पर आंटन का आशय यह है किक इन सीटों पर आंटन पू्ቓ2तः मेरिरट के आार पर किकया जाएगा, जिजसमें संस्ቕኋागत (Institutional) एं गैर- संस्ቕኋागत (Non-Institutional) 14 दोनों ही कोटे के पा्ቔ अभ्यቕኋ= समान रूप से पा्ቔ होंगे।।” 22. Since, Rule 11(a) and (b) of the said Rules of 2025 has been amended and the respondent No.3 has cancelled the earlier round of counseling and allotment of seats, the petitioner cannot claim as a indefeasible right that she should be entitled for the allotted seat of Medical P.G. Course, on which she has already taken admission. 23. In view of the foregoing analysis, this Court finds no merit in the present writ petition. The impugned orders dated 22.01.2026 and 23.01.2026 issued by the respondent–State have been passed in faithful compliance with the law laid down by the Hon’ble Supreme Court in the case of “Dr. Tanvi Behl” (supra) and the clarificatory order passed by this Court in WPC No. 5937 of 2025 and MCC No. 40 of 2026. The State has acted within its constitutional and statutory domain to ensure that admissions to Post Graduate Medical Courses are made strictly in accordance with settled legal principles and constitutional mandates. It is well settled that no vested or indefeasible right accrues merely on the basis of provisional allotment or admission, particularly when such admissions are subject to judicial scrutiny and correction. 24. Accordingly, the writ petition is dismissed. 25. It is further directed that this order shall have the effect “in rem” and shall apply uniformly to all similarly situated candidates. The issues adjudicated herein stand conclusively settled, and 15 no separate or successive petitions raising identical grounds shall be entertained by this Court, so as to prevent multiplicity of litigation and to ensure certainty, finality and discipline in the Post Graduate medical admission process.” 12. Upon a comprehensive consideration of the pleadings, the rival submissions advanced by learned counsel for the parties, the statutory framework governing Post Graduate medical admissions, and the binding judicial precedents holding the field, this Court is of the considered opinion that the controversy raised in the present writ petition is no longer res integra. The issues sought to be agitated by the petitioner stand squarely covered and conclusively answered by the judgment dated 27.01.2026 passed by this Court in WPC No. 367 of 2026 (Anushka Yadav v. State of Chhattisgarh and others), wherein identical challenges to the amendment of Rule 11 of the Chhattisgarh Medical Post Graduate Admission Rules, 2025 and the consequent cancellation of counselling were repelled after detailed examination of the very same judgments, notifications and statutory provisions relied upon by the petitioner herein. Judicial discipline, consistency and comity demand that this Court follows the said binding precedent, particularly when no distinguishing feature in facts or law has been demonstrated. 13. This Court further holds that the amendment dated 22.01.2026 to Rule 11 of the Rules, 2025 cannot be said to be arbitrary, unconstitutional or violative of Article 14 of the Constitution of 16 India. On the contrary, the amendment has been brought to realign the admission process with the authoritative law laid down by the Hon’ble Supreme Court in Dr. Tanvi Behl (supra) and the clarificatory directions issued by this Court in MCC No. 40 of 2026. The State Government, in exercise of its legislative and executive competence, was well within its jurisdiction to rectify the seat matrix and counselling process in order to remove constitutional infirmities and to ensure that institutional preference remains confined within permissible limits. Merely because admissions had been provisionally granted in earlier counselling rounds does not crystallise any vested or indefeasible right in favour of the petitioner. 14. It is a settled principle of law that admissions granted subject to statutory rules and judicial scrutiny are always provisional and conditional in nature, and are liable to be altered, modified or even cancelled if the governing rules undergo valid amendment or are found inconsistent with constitutional or statutory mandates. The petitioner, having participated in the counselling process with open eyes and full knowledge that the admission was subject to the final outcome of pending litigations and rule amendments, cannot invoke the doctrine of estoppel or legitimate expectation against the State. The larger public interest in maintaining a constitutionally compliant, merit-based and uniform admission process must prevail over individual equities. 17 15. The cancellation of the first and second rounds of counselling and allotments pursuant to the amendment dated 22.01.2026 cannot, therefore, be construed as illegal or arbitrary. Rather, the said action was a necessary administrative consequence flowing from the restructuring of the reservation roster and seat distribution. The clarification issued on 23.01.2026 further demonstrates that the State has consciously ensured that the “open category” seats are allotted strictly on merit, without institutional discrimination, thereby fully conforming to the ratio of Dr. Tanvi Behl (supra). This Court finds no element of mala fides, colourable exercise of power or contumacious conduct on the part of the respondent– State. 16. In view of the foregoing discussion and respectfully following the judgment rendered in WPC No. 367 of 2026 (Anushka Yadav v. State of Chhattisgarh and others), this Court finds no merit in the present writ petition. The same is accordingly dismissed. No costs. 17. It is further clarified that this judgment shall operate in rem and shall apply uniformly to all similarly situated candidates. All issues arising out of or connected with the amendment of Rule 11 of the Chhattisgarh Medical Post Graduate Admission Rules, 2025 and the consequential counselling process stand conclusively settled. No fresh or successive writ petitions raising identical or substantially similar grounds shall be entertained by this Court, so 18 as to prevent multiplicity of litigation and to ensure certainty, finality and discipline in the Post Graduate medical admission process. Sd/- Sd/- (Ravindra Kumar Agrawal) (Ramesh Sinha) Judge Chief Justice Anu