State of Punjab v. Davinder Singh
“States Can Sub-Classify SC/STs for More Equitable Reservation”
TL;DR
A seven-judge Constitution Bench of the Supreme Court, by a 6:1 majority, held that State governments can create sub-classifications within Scheduled Castes (SCs) and Scheduled Tribes (STs) for reservation in public employment and education. The judgment overruled the 2004 E.V. Chinnaiah decision which had held that SCs form a homogeneous group that cannot be subdivided. States can now prioritize more backward sub-groups within SCs/STs.
The Bottom Line
States can now create sub-quotas within SC/ST reservations to ensure that benefits reach the most disadvantaged sub-groups. The more backward castes within the SC category can be given preference over relatively advanced ones.
Case Timeline
The journey from FIR to Supreme Court verdict
Punjab Notification
Punjab divided SC reservation: 50% for Balmikis/Mazhabi Sikhs, 50% for others
Punjab Notification
Punjab divided SC reservation: 50% for Balmikis/Mazhabi Sikhs, 50% for others
E.V. Chinnaiah Judgment
Five-judge bench held SCs are homogeneous, cannot be sub-classified
E.V. Chinnaiah Judgment
Five-judge bench held SCs are homogeneous, cannot be sub-classified
Reference to Seven-Judge Bench
Five-judge bench referred matter to larger bench to reconsider Chinnaiah
Reference to Seven-Judge Bench
Five-judge bench referred matter to larger bench to reconsider Chinnaiah
Constitution Bench Judgment
Seven-judge bench overruled Chinnaiah by 6:1 majority
Constitution Bench Judgment
Seven-judge bench overruled Chinnaiah by 6:1 majority
The Story
In 1975, the Punjab government divided its 25% SC reservation into two categories: half for Balmikis and Mazhabi Sikhs (considered most disadvantaged), and the other half for remaining SC groups.
In 2004, a five-judge bench in E.V. Chinnaiah v. State of Andhra Pradesh struck down Andhra Pradesh's similar sub-classification, holding that the Presidential list of SCs under Article 341 creates a homogeneous class that cannot be subdivided by States.
Punjab's 1975 notification was also challenged based on Chinnaiah. The Punjab and Haryana High Court struck down the sub-classification. Punjab appealed to the Supreme Court.
Given the importance of the issue and the need to reconsider Chinnaiah, the matter was referred to a seven-judge Constitution Bench. After detailed hearings, the Bench delivered a 6:1 majority verdict overruling Chinnaiah and upholding the power of States to sub-classify SCs/STs.
Legal Issues
Click each question to reveal the Supreme Court's answer
Arguments
The battle of arguments before the Supreme Court
Petitioner
Vihaan Kumar
Substantive equality requires sub-classification
Within SCs, some castes have benefited disproportionately from reservation while others remain severely disadvantaged. Sub-classification ensures equitable distribution.
State's power under Articles 15 and 16
These are enabling provisions that allow States to make special provisions for backward classes. This includes the power to sub-classify.
Presidential list identifies, not distributes
Article 341 only identifies which castes are SCs. How benefits are distributed among them is for the State to decide under Articles 15/16.
Respondent
State of Haryana
Chinnaiah settled the law
E.V. Chinnaiah categorically held that SCs form a homogeneous class. This has been the law for 20 years.
Presidential list is sacrosanct
Only Parliament can include/exclude castes from the SC list. States cannot create sub-categories within this constitutional class.
Division will create hierarchy
Sub-classification will create hierarchies among SC communities and lead to inter-caste conflicts.
Court's Analysis
How the Court reasoned its decision
The seven-judge bench conducted a comprehensive review of reservation jurisprudence, examining the purpose of affirmative action and the reality of intra-group disparities within SCs. The majority held that formal equality (treating all SCs identically) has failed to achieve substantive equality, as benefits have been cornered by relatively advanced sub-groups. Sub-classification is a tool to correct this imbalance.
Treating unequals as equals perpetuates inequality. If within the SC category, some groups are more backward than others, treating them all identically defeats the purpose of reservation.
Philosophical basis for sub-classification.
The State's power to sub-classify is derived from Articles 15 and 16, which are distinct from the President's power under Article 341 to identify SCs.
Constitutional basis distinguishing identification from distribution.
Sub-classification must be rooted in rational basis indicating social backwardness. States must collect empirical data showing inadequate representation of certain sub-groups.
Requirement for data-backed sub-classification.
The Verdict
Relief Granted
Punjab's 1975 notification creating sub-classification upheld. States across India can now implement similar measures.
Directions Issued
- States can sub-classify SCs/STs for reservation purposes
- Sub-classification must be based on rational criteria and empirical data
- States cannot reserve 100% seats exclusively for any sub-class
- Two models permitted: preference model (prioritizing sub-castes) or exclusive model (specific seat reservation)
- Creamy layer principle applies to SCs/STs
- E.V. Chinnaiah (2004) is overruled
Key Legal Principles Established
States can sub-classify SCs/STs for reservation in employment and education.
Sub-classification does not tinker with the Presidential List under Article 341.
SCs/STs are not a homogeneous class - varying degrees of backwardness exist.
Sub-classification must be based on rational criteria and empirical data.
States cannot reserve 100% of seats for any one sub-group.
Creamy layer exclusion applies to SCs/STs.
E.V. Chinnaiah (2004) is overruled.
Two models: preference model or exclusive reservation model.
Key Takeaways
What different people should know from this case
- If you belong to a more disadvantaged sub-group within SCs/STs, you may get preference in reservation.
- State governments can now create sub-quotas within SC/ST reservations.
- The most marginalized communities within SCs/STs will get targeted benefits.
- This does not affect overall SC/ST reservation percentage - only how it is distributed.
- If you're in the "creamy layer" of SCs/STs, you may be excluded from reservation in promotions.
Legal Framework
Applicable laws and provisions
Constitutional Provisions
Article 341
Constitution of India
“(1) The President may with respect to any State or Union territory, and where it is a State, after consultation with the Governor thereof, by public notification, specify the castes, races or tribes or parts of or groups within castes, races or tribes which shall for the purposes of this Constitution be deemed to be Scheduled Castes...”
Relevance: Presidential power to identify SCs - distinct from State power to distribute benefits.
Article 15(4)
Constitution of India
“Nothing in this article or in clause (2) of article 29 shall prevent the State from making any special provision for the advancement of any socially and educationally backward classes of citizens or for the Scheduled Castes and the Scheduled Tribes.”
Relevance: Enables State to make special provisions for SCs/STs including sub-classification.
Article 16(4)
Constitution of India
“Nothing in this article shall prevent the State from making any provision for the reservation of appointments or posts in favour of any backward class of citizens which, in the opinion of the State, is not adequately represented in the services under the State.”
Relevance: Enables reservation in public employment based on inadequacy of representation.
Related Cases & Precedents
E.V. Chinnaiah v. State of Andhra Pradesh
overruled(2005) 1 SCC 394
Five-judge bench held SCs form homogeneous class that cannot be sub-classified. Now overruled.
Indra Sawhney v. Union of India
cited(1992) Supp 3 SCC 217
Nine-judge bench judgment on reservation - introduced creamy layer concept.
Jarnail Singh v. Lachhmi Narain Gupta
cited(2018) 10 SCC 396
Applied creamy layer to SCs/STs for reservation in promotions.
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