Court case(2002) 1 SCC 428

AIIMS reserved 33 per cent of its post-graduate seats for its own MBBS graduates and, within that, distributed seats discipline-wise, with the result that institutional candidates with far lower marks got seats in preferred specialities while meritorious outsiders were excluded. The AIIMS Students' Union and other candidates challenged the scheme as violating Article 14.

Lahoti J struck the scheme down. Institutional preference may be permissible to a limited extent at the post-graduate level, but a 33 per cent reservation combined with discipline-wise allotment that sacrificed merit at a premier national institute was arbitrary and offended Article 14. Importantly, the Court invoked Article 51A(j), the duty to strive towards excellence, and held that fundamental duties, though not enforceable by writ, "cast a duty on every citizen" and are "constitutional means" that courts may use in interpreting the Constitution and testing the reasonableness of State action. A citizen's duty to excel is also the State's obligation not to stifle excellence.