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The Caste Puzzle: An Analysis Of The Sub- Categorization Judgment




Varun K Chopra, Former Deputy Advocate General, State of MP, and arguing counsel before the Supreme Court of India.


Case: State of Punjab & Ors. v. Davinder Singh & Ors. (C.A. 2317/ 2011)


On 1st of August, 2024, a 6:1 majority of the Supreme Court ruled that states have the authority to implement sub-classification within the Scheduled Castes (SC) and Scheduled Tribes (ST) categories. The ruling permits states to create sub-groups within these categories, allowing for a system of “quotas within quotas” to provide preferential treatment to more disadvantaged sub-groups among SCs and STs.


The case originated from a 1975 notification issued by the Punjab government, which was later re-enacted as a 2006 law. This law reserved half of the Scheduled Caste quota for two specific groups: Balmikis and Mazhabi Sikhs. The Punjab and Haryana High Court had previously declared this law unconstitutional, and similar laws in Haryana and Tamil Nadu faced the same outcome. The High Courts based their decisions on the Supreme Court’s ruling in the case of E.V. Chinnaiah v State of Andhra Pradesh1, which had established that Scheduled Caste groups were considered a “homogenous group” as per the Presidential List under Article 3412 of the Indian Constitution.


Punjab contested the High Court’s decision and challenged the validity of the Chinnaiah3 ruling. More than thirty years earlier, in Indra Sawhney v Union of India (1992), the Supreme Court had affirmed the division of “backward classes” into “backward classes” and “more backward classes.” This landmark decision had confirmed reservations for Other Backward Classes (OBCs) and excluded the ‘creamy layer’ within OBCs, as recommended by the Mandal Commission Report. The Chinnaiah4 ruling had asserted that sub-classification within the Scheduled Caste category would infringe upon Article 14 of the Constitution, arguing that the Indra Sawhney judgment had only addressed categorization within the OBC category.

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Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878

Website: www.ijllr.com

Accessibility: Open Access

License: Creative Commons 4.0

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