Winners' Dashboard
Demo Classes
+91 99714 44054
info@manulawclasses.com
Facts:
The Punjab Scheduled Castes and Backward Classes (Reservation in Services) Act, 2006, allocated 50% of SC-reserved vacancies to Balmikis and Mazhabi Sikhs, a provision intended to benefit the most marginalized within the Scheduled Castes (SCs). This provision was challenged and struck down by the Punjab and Haryana High Court, relying on the Supreme Court’s ruling in E.V. Chinnaiah v. State of A.P., (2005) 1 SCC 394. In Chinnaiah, the Court held that SCs constitute an internally homogeneous class by virtue of their inclusion in the Presidential list and cannot be further classified for reservation purposes, as such sub-classification would amount to a “micro-classification” violating Article 14 of the Constitution.
Issue:- Whether the State can make sub-classifications within Scheduled Castes to provide separate reservations for more backward groups within the SC category under Articles 15(4) and 16(4) of the Constitution.
Decision:- The seven-judge Constitution Bench ruled by a 6:1 majority that sub-classification within SCs is permissible under Articles 14, 15, and 16 of the Constitution, provided that:
- There is a rational basis for differentiation (intelligible differentia).
- This differentiation is connected to the purpose of the reservation law.
The Court overruled Chinnaiah (supra), holding that Article 341 of the Constitution does not create a homogeneous class of SCs, and states can further classify them if justified. The judgment aligned with the principles in Indra Sawhney v. Union of India, recognizing that SCs are a socially heterogeneous group. The ruling allows states to create sub-classifications within SCs to ensure equitable distribution of reservation benefits, as long as the classification does not result in the exclusion of certain SC groups from all reserved seats.
