Introduction:
- The Supreme Court, in a significant ruling, has redefined how reservations for Scheduled Castes (SCs) and Scheduled Tribes (STs) can be structured.
- In a 6:1 majority verdict, the Bench, led by Chief Justice of India D Y Chandrachud, permitted states to create sub-classifications within SC and ST categories to ensure more targeted benefits for the most disadvantaged groups within these categories.
- The judgment was largely supported, with Justice Bela Trivedi being the sole dissenter.
Body:
Constitutional Framework:
- Article 341 of the Constitution empowers the President to notify which “castes, races, or tribes” qualify as SCs, recognizing their historical disadvantages due to untouchability.
- An example is the 1975 notification in Punjab that prioritized the Balmiki and Mazhabi Sikh communities in SC reservations. This was later contested following a similar ruling in Andhra Pradesh in the E V Chinnaiah case.
Judicial Precedents:
- The Supreme Court, in E V Chinnaiah, had previously held that SCs must be treated uniformly, as any differentiation could violate the right to equality under Article 14.
- However, the recent ruling challenges this view, asserting that uniformity in the Presidential list does not preclude sub-classification to address varying levels of backwardness.
Key Issues:
- Equality Among SCs: The core question was whether all castes within the SC list should receive the same benefits. The Court recognized that different castes might have different levels of backwardness, justifying sub-classification.
- State Authority: The Court’s earlier stance in E V Chinnaiah restricted states from sub-classifying SCs, but the new judgment allows states to do so under Articles 15 and 16, provided it’s based on identifiable degrees of social backwardness.
- Sub-Classification Criteria: The judgment emphasized the need for “effective representation” rather than mere numerical representation in public services. States must provide quantifiable data to justify sub-classification.
- Creamy Layer Debate: Justice Gavai supported applying the ‘creamy layer’ principle to SCs, a concept already in place for Other Backward Classes (OBCs). This approach ensures that only the most disadvantaged within the SC community benefit from reservations.
Conclusion:
- The Supreme Court’s recent judgment marks a pivotal shift in how reservations for SCs and STs can be implemented, allowing for greater flexibility in addressing the unique needs of different communities within these categories.
- By permitting sub-classifications, the ruling aims to ensure that the most marginalized within the SC and ST groups receive the benefits intended for them, aligning with the principles of social justice and equality enshrined in the Constitution.