The Supreme Court has delivered a significant judgement on the issue of sub-classification within the Scheduled Castes (SCs) and Scheduled Tribes (STs) reservations. In a ruling made on Thursday, the Court affirmed that state governments have the authority to implement sub-classification among these groups. This landmark decision marks a departure from the previous legal stance that considered SCs and STs as homogenous classes.
The seven-judge bench, led by Chief Justice of India (CJI) DY Chandrachud, overruled the earlier judgement in the EV Chinnaiah case, which had deemed sub-classification impermissible. The majority verdict, with a ratio of 6:1, recognized that states can create sub-categories within SCs and STs, provided they have adequate data to support such classifications.
The Supreme Court's decision highlights that the determination of whether a sub-classification is valid should be based on effective representation rather than mere numbers. This means that the effectiveness of the representation of these sub-categories in public services must be considered to justify any sub-classification.
Chief Justice Chandrachud, along with Justice Manoj Misra, stated that Article 14 of the Constitution permits sub-classification if the class in question is not similarly situated. The Court emphasised that states must prove that different castes within the SC and ST categories experience varying levels of social backwardness. This must be demonstrated through quantifiable data and not merely through traditional occupations or assumptions.
Justice Bela M. Trivedi, however, dissented from the majority opinion. She argued that the judgement in the EV Chinnaiah case, which disallowed sub-classification, was correct and should be upheld. Justice Trivedi contended that the SCs and STs are constitutionally recognized as a homogenous class and that any attempt to sub-classify them would undermine their collective identity.
The ruling also addressed the issue of whether sub-classification could result in seats being allocated specifically for each subclass within the broader SC category. The Court opined that while sub-classification is permissible, it does not mean that every subclass should receive separate reservations. Instead, if the social backwardness of different classes is comparable, they should be grouped together for the purposes of reservation.
In addition, the judgement underscores that the principle of sub-classification must be based on a rational principle that directly relates to the purpose of the classification. This means that states need to justify sub-classification with concrete evidence showing the differing levels of backwardness among the castes.
Justice BR Gavai supported the majority judgement but emphasised that while sub-classification is allowed, it cannot lead to reserving 100% of the seats for a specific subclass to the exclusion of others. The state must balance reservations within the broader SC category and ensure that no single sub-class dominates the reserved seats.
Overall, the Supreme Court's decision represents a shift in the interpretation of reservations for SCs and STs. It opens the door for states to create sub-categories based on empirical data and effective representation, provided they adhere to constitutional principles and rational justifications.
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