Chhattisgarh High Court dismisses NEET plea, upholds 30% women’s reservation in MBBS seat allotment dispute

News Citation : 2026 LN (HC) 141 | 2026:CGHC:4104-DB

January 23, 2026 : The High Court of Chhattisgarh has dismissed a writ petition filed by a NEET aspirant who challenged the allotment of an MBBS seat under the Scheduled Caste category during the 2025 Mop-Up Round counselling process.

The case, Arman Ogrey vs State of Chhattisgarh & Others (WPC No. 6105 of 2025), arose from a dispute over seat allocation at Bharatratna Late Shri Atal Bihari Vajpayee Memorial Government Medical College, Rajnandgaon.

The petitioner, Arman Ogrey, appeared in NEET-UG 2025 for admission to MBBS under the State Government quota. He secured a higher rank in the SC category compared to another candidate, Liza Mahima. When the provisional Mop-Up Round allotment list was published on November 5, 2025, the MBBS seat in question was allotted to Mahima instead of Ogrey.

Ogrey argued that the seat was listed as an SC category seat without any sub-classification. Since he ranked higher in merit, he claimed the allotment violated constitutional guarantees under Articles 14 and 15. He sought cancellation of the seat granted to Mahima and requested that it be allotted to him.

The State defended the allotment, pointing to Rule 5(2) of the Chhattisgarh Medical, Dental and Physiotherapy Under Graduate Admission Rules, 2025. The rule provides for 30 percent horizontal reservation for women across all categories, including Scheduled Castes.

According to the State, the seat had initially been allotted in the second counselling round to an SC female candidate under the women’s quota. When that candidate did not join, the seat was carried forward to the Mop-Up Round under the same reservation category. Since Liza Mahima also belonged to the SC female category, the seat was validly allotted to her.

The State emphasized that once a seat is operated under horizontal reservation, it cannot later be converted or de-reserved. Merit, it argued, operates subject to reservation rules.

A Division Bench comprising Chief Justice Ramesh Sinha and Justice Ravindra Kumar Agrawal examined the statutory framework and relevant Supreme Court precedents, including Pramati Educational & Cultural Trust v. Union of India and State of Kerala v. N.M. Thomas.

The Court noted that horizontal reservation for women is clearly mandated under the 2025 Admission Rules. It observed that the seat in question had already been operated under the SC women category during the earlier counselling round. When the initially allotted candidate did not join, the seat retained its character and could not be reclassified as a general SC seat.

The Bench held that the petitioner’s higher merit could not override properly applied horizontal reservation. Since the allotment followed the statutory reservation framework, there was no arbitrariness or illegality in granting the seat to Mahima. The writ petition was accordingly dismissed.

The ruling reinforces that vertical merit lists do not override horizontal reservation policies. Once a seat is filled under a horizontal quota such as women’s reservation, its character continues even if it is later carried forward. For candidates participating in NEET counselling, the judgment clarifies that merit operates within the structure of reservation rules, not outside it.

Case Reference : WPC No. 6105 of 2025, Arman Ogrey vs State of Chhattisgarh and Others; for the Petitioner: Mr. Bidya Nand Mishra, Advocate; for the Respondents/State: Mr. Shashank Thakur, Additional Advocate General; for Respondent No. 5: Mr. Siddharth Pandey, Advocate.