[BREAKING] “Sub-Classification of Scheduled Castes/ Scheduled Tribes Permissible”: SC (By 6:1 Majority) Overrules EV Chinnaiah

In a landmark judgment, the Supreme Court Today (August 1st) upheld the power of States to sub-classify reserved category groups, viz. the Scheduled Castes and Scheduled Tribes (SC/STs), into different groups based on their inter se backwardness for extending the benefits of reservation.

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NEW DELHI: In a landmark judgment today, the Supreme Court upheld the authority of States to sub-classify reserved category groups, specifically the Scheduled Castes and Scheduled Tribes (SC/STs), into different groups based on their relative backwardness to extend the benefits of reservation.

The seven-judge Constitution bench, comprising Chief Justice of India (CJI) DY Chandrachud and Justices BR Gavai, Vikram Nath, Bela M Trivedi, Pankaj Mithal, Manoj Misra, and Satish Chandra Sharma, overruled the 2005 judgment of EV Chinnaiah v. State of Andhra Pradesh.

The earlier judgment had held that sub-classification of SC/STs was contrary to Article 341 of the Constitution, which grants the President the authority to prepare the list of SC/STs.

In her dissenting opinion, Justice Bela M Trivedi ruled that such sub-classification is not permissible. However, the majority upheld the sub-classification, stating,

“The members of SC/ST are not often able to climb up the ladder due to the systemic discrimination faced. Article 14 permits sub-classification of caste. Court must check if a class is homogeneous or and a class not integrated for a purpose can be further classified.”

The Court validated laws that provide for such sub-classification in Punjab, Tamil Nadu, and other States. Specifically, the Court upheld the Punjab Scheduled Caste and Backward Classes (Reservation in Services) Act, 2006, and the Tamil Nadu Arunthathiyars (Special Reservation of Seats in Educational Institutions and of Appointments or Posts in the Services under the State within the Reservation for the Scheduled Castes) Act, 2009. These laws provide special reservations for sub-groups within the broader category of Scheduled Castes.

The judgment originated from a challenge to the validity of the Punjab Scheduled Caste and Backward Classes (Reservation in Services) Act, 2006. This law was initially struck down by the Punjab and Haryana High Court, prompting the Punjab government to appeal to the Supreme Court.

The laws were contested based on the 2005 Constitution Bench judgment in EV Chinnaiah v. State of Andhra Pradesh, which asserted that all SCs form a homogeneous class that cannot be sub-divided. The matter was referred to a seven-judge bench in 2020 after a five-judge bench expressed disagreement with the EV Chinnaiah decision, which had declared sub-categorisation of castes unconstitutional.

During the hearings, the CJI distinguished between “sub-classification” and “sub-categorisation” of communities, noting that inclusion or exclusion of communities should not be reduced to appeasement politics. The Court observed that the Punjab government’s law might have aimed to exclude candidates from the reserved category who had already benefited from existing relaxations.

The Central government supported reservations for downtrodden classes in India and favored sub-classification. States argued that sub-classification of SC/STs does not violate Article 341, as it does not alter the list prepared by the President.

They contended that Article 341 pertains solely to the preparation of the list of SCs and does not prevent States from sub-classifying SCs based on their backwardness to extend reservation benefits.

Ultimately, the Court’s ruling affirmed that States have the power to sub-classify reserved category groups to address the varying levels of backwardness within these groups and ensure more equitable distribution of reservation benefits.

Click Here to Read Previous Reports on Sub-Classification of SC/ST

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