New Delhi: In a landmark judgment, the Supreme Court upheld the power of states to sub-classify reserved category groups, specifically the Scheduled Castes (SC) and Scheduled Tribes (ST), into different groups based on their inter se backwardness. The decision allows for separate quotas within the SC-ST category, addressing the pressing need for empowerment of historically marginalized communities.
Background and Rationale
The constitutional bench, comprising seven judges led by Chief Justice of India (CJI) DY Chandrachud, issued the order with a majority of 6:1. Justice BR Gavai emphasized that the ground reality of the country cannot be ignored. Within the SC-ST category, certain groups have faced centuries of oppression, necessitating thoughtful consideration. The sub-classification recognizes that some sub-groups within the larger SC-ST community experience more severe discrimination.
Overruling Previous Precedent
The judgment overruled the 2005 decision in EV Chinnaiah v. State of Andhra Pradesh, which had held that sub-classification of SC/STs was contrary to Article 341 of the Constitution. Article 341 confers the right of the President to prepare the list of SC/STs. However, the Supreme Court now acknowledges that sub-classification is permissible under Article 14, which allows for classification based on relevant criteria. The Court emphasized that a class not integrated for a specific purpose can be further classified.
Validity of State Laws
The Court upheld the validity of laws that provide for sub-classification in various states. Notably, the Punjab Scheduled Caste and Backward Classes (Reservation in Services) Act, 2006, which the Punjab and Haryana High Court previously struck down, has been upheld. Similarly, the Tamil Nadu Arunthathiyars (Special Reservation of Seats in Educational Institutions and Appointments or Posts in the Services under the State within the Reservation for the Scheduled Castes) Act, 2009, which provides reservation for Arunthathiyars within the State’s 18% SC reservation, was also upheld.
A Step Towards Empowerment
This decision marks a significant step towards empowering historically disadvantaged communities. By allowing sub-classification, the Supreme Court recognizes certain sub-groups unique challenges within the SC-ST category and aims to address their specific needs. It also ensures that reservation benefits are more effectively distributed, promoting social justice and inclusivity.
