Supreme Court Allows Sub-Classification of Scheduled Castes for Separate Quotas, Overrules E.V. Chinnaiah Judgment.
A seven-judge bench of the Supreme Court, including Chief Justice of India DY Chandrachud, Justices BR Gavai, Vikram Nath, Bela M. Trivedi, Pankaj Mithal, Manoj Misra, and Satish Chandra Sharma, ruled 6-1 in favor of allowing sub-classification of Scheduled Castes (SCs) to create separate quotas for the more disadvantaged groups within the SC categories.
The Constitution Bench examined two main issues:
- Whether sub-classification within the reserved castes should be permitted.
- The validity of the 2005 decision in E.V. Chinnaiah v. State of Andhra Pradesh, which declared that SCs notified under Article 341 formed a single homogenous group that could not be further sub-categorized.
Chief Justice Chandrachud noted that all six majority judgments concurred, overruling the E.V. Chinnaiah decision that sub-classification was impermissible. Justice Bela Trivedi dissented.
The Court clarified that while sub-classification is allowed, the State cannot allocate 100% reservation to a sub-class and must justify the sub-classification with empirical data showing inadequate representation of the sub-class.
Chief Justice Chandrachud’s opinion stated that sub-classification does not violate Articles 14 or 341. Justice BR Gavai, in his concurring opinion, emphasized the State’s duty to provide preferential treatment to more disadvantaged communities within the SC/ST categories, acknowledging that only a few within these categories have benefited from reservations and recognizing the differing levels of historical oppression.
The E.V. Chinnaiah judgment erred by assuming that Article 341 was the basis for reservation, whereas Article 341 only pertains to the identification of castes for reservation purposes.
Case Details : State Of Punjab And Ors. v Davinder Singh And Ors. C.A. No. 2317/2011
Citation : 2024 (SC) 538
