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Supreme Court upheld States’ right to sub-categorise SCs for quota benefits

  • August 2, 2024
  • Posted by: OptimizeIAS Team
  • Category: DPN Topics
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Supreme Court upheld States’ right to sub-categorise SCs for quota benefits

Subject: Polity

Sec: Constitution

Context:

In a 6:1 majority ruling, the Supreme Court on August 1 held that sub-classification within the Scheduled Castes (SCs) and Scheduled Tribes (STs) categories is permissible to extend the benefit of affirmative action. However, the seven-judge Bench headed by Chief Justice of India (CJI) D.Y. Chandrachud underscored that this must be based on “quantifiable and demonstrable data” instead of political expediency.

More on News: 

  • In a separate but concurring ruling, Justice B.R. Gavai called upon States to devise a policy to identify and exclude the “creamy layer” (wealthier and more advanced members of a backward class) within the SC/ST categories from reservation benefits. 
  • Accordingly, the top court overruled a 2004 verdict by a five-judge Bench in V. Chinnaiah v. State of Andhra Pradesh which had held that such sub-classification was not permissible since the SC/STs constituted “homogenous” classes.
  • Existing reservations being ‘sub-classified’ by a State, the Punjab government in 1975 issueda circular dividing its 25% SC reservation at that time into two categories. The first category reserved seats exclusively for the Balmiki and Mazhabi Sikh communities, granting them first preference for reservations in education and public employment.
  • The second category included all other SC communities. This caused considerable outrage since the Balmikis and Mazhabi Sikhs were considered two of the most economically and educationally backward communities in the State.
  • After remaining in force for nearly 30 years, the circular encountered legal trouble in 2004 when a five-judge Bench of the Supreme Court struck down a similar law introduced by Andhra Pradesh in 2000.
  • In V. Chinnaiah, the Andhra Pradesh Scheduled Castes (Rationalisation of Reservations) Act, 2000 was found to be violative of the right to equality under Article 14 of the Constitution.
  • The legislation was also found to offend Article 341 of the Constitution, which allows the President to notify a list of SCs for each State to extend reservation benefits.
  • Article 341(2) stipulates that only Parliament can include or exclude “any caste, race, or tribe” from this list of SCs. The Bench reasoned that this provision precludes States from altering the list, including through the sub-classification of reserved categories.
  • The Punjab government remained persistent and enacted a new law i.e. the Punjab Scheduled Castes and Backward Classes (Reservation in Services) Act, 2006, which once again provided first preference to the Balmikis and Mazhabi Sikhs.
  • Article 14 of the Constitution obligates the State to ensure that the same law applies only to those who are “similarly situated”, the judges reasoned that sub-classification within the SC/ST categories does not fall foul of the right to equality.
  • The verdict traced the power of the States to undertake such an exercise to Articles 15(4) and 16(4) of the Constitution which permits the introduction of “special provisions” in favour of any backward class of citizens. Justice Gavai pointed out that the right to equality of opportunity under Article 16 of the Constitution must account for the differing social positions of various communities.

SC’s Verdict on Sub-Classifications of SCs and STs:

  • Sub-Classifications Permitted: The Court ruled that states are constitutionally allowed to sub-classify SCs and STs based on varying levels of backwardness.
    • The seven-judge Bench ruled that states can now sub-classify SCs within the 15% reservation quota to provide better support for the most disadvantaged groups.
    • Chief Justice of India emphasised the difference between “sub-classification” and “sub-categorisation,” cautioning against using these classifications for political appeasement rather than genuine upliftment.
      • The Court noted that sub-classification should be based on empirical data and historical evidence of systemic discrimination, rather than arbitrary or political reasons.
    • States must base their sub-classification on empirical evidence to ensure fairness and effectiveness.
    • The Court clarified that 100% reservation for any sub-class is not permissible. State decisions on sub-classification are subject to judicial review to prevent political misuse.
    • The Supreme Court has ruled that the ‘creamy layer’ principle, previously applied only to Other Backward Classes (OBCs) (as highlighted in Indra sawhney Case) should now also be applied to SCs and STs. 
      • This means states must identify and exclude the creamy layer within SCs and STs from reservation benefits. The judgement responds to the need for a more nuanced approach to reservations, ensuring that benefits reach those who are truly disadvantaged.
    • The court stated that Reservation has to be limited only to the first generation.
      • If any generation in the family has taken advantage of the reservation and achieved a higher status, the benefit of reservation would not be logically available to the second generation.

Constitutional Stance:

  • Articles 341 and 342:It grants powers to the President to notify SC and ST lists and to Parliament to create these lists.
    • However, there is no explicit prohibition against sub-categorisation.
      • Article 341(1) of the Constitution gives the President the power to “specify the castes, races or tribes” in a state, which shall “for the purposes of this Constitution be deemed to be Scheduled Castes in relation to that State or Union territory, as the case may be”. Following such a notification, Article 341(2) states that only Parliament can include or exclude “any caste, race or tribe” from the list of SCs.
Polity Supreme Court upheld States’ right to sub-categorise SCs for quota benefits

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