Citation: (2020) 8 SCC 1
Date of Judgment: 27 August 2020
Bench: Justices Arun Mishra, Indira Banerjee, Vineet Saran, M.R. Shah, Aniruddha Bose
Facts of the Case:
- In order to more fairly distribute the advantages of reservation, the State of Punjab passed legislation in 2006 and published notifications allowing for internal sub-classification among the Scheduled Castes (SCs).
- The belief that some castes among the SCs were comparatively better developed and had monopolized the majority of reservation advantages, putting other, more underdeveloped SC communities at a disadvantage, served as the basis for this action[1].
- To ensure that the most disadvantaged castes were adequately represented in public jobs and education, a sub-quota or category was to be established within SCs.
- But this action was contested in court as going against the Supreme Court’s previous ruling in E.V. Chinnaiah v. State of Andhra Pradesh (2005) 1 SCC 394, which maintained that SCs notified under Article 341 must be regarded as a homogenous class and that no sub-classification is allowed by the constitution.
- The Punjab and Haryana High Court invalidated Punjab’s action as unconstitutional, citing Chinnaiah as support. The Supreme Court heard the case after the State of Punjab appealed the ruling.
Issues Raised:
- In order to guarantee a fair distribution of reservation benefits, is it possible for the State to create subclassifications under the Scheduled Castes category?
- Does this subcategorization go against Article 341 of the Constitution, which gives the President the authority to announce the Scheduled Castes list?
- Should a larger bench reexamine the E.V. Chinnaiah ruling?
Contentions of the Parties:
Petitioner (State of Punjab):
- Contended that:
- The State may take affirmative action for the advancement of socially and educationally backward sections under Articles 16(4) and 15(4).
- Reservations are meant to guarantee the underprivileged are represented in a genuine and significant way, not just through formal inclusion.
- Without sub-classification, the goal of social fairness is undermined because a small number of powerful castes within SCs monopolise the benefits.
- Article 14 permits sub-classification based on logical and understandable differentiation.
Respondents (Davinder Singh & Ors.):
- Made extensive use of the Chinnaiah ruling in their argument that states are not allowed to alter or subcategorise a caste’s inclusion in the SC list under Article 341 once the President adds it.
- Any internal classification is unconstitutional because the entire SC list is a single class.
- The SC community would become fragmented and divided as a result of sub-classification.
- By attempting to modify or change the SC list, which is a Union subject, states are going beyond their authority.
Judgment & Rationale:
The Supreme Court’s Views:
- The Court pointed out that reserve is a tool to guarantee true equality by uplifting the most marginalized groups, not an objective in and of itself.
- Not all castes on the SC list are equally backward just because they are listed.
- The Constitution does not forbid sub-classification, which is actually required to stop more developed SCs from continuously gaining advantages at the expense of the least developed.
- The Court underlined that:
- The President may designate which castes are SCs under Article 342, but the State is still free to distribute resources or benefits among them in a different way.
- Ground realities contradict the notion that SCs are a homogeneous group.
Decision:
- The Court left the question of whether sub-classification was constitutional open and instead referred the Chinnaiah ruling to a larger bench for authoritative interpretation.
- The Bench acknowledged that states’ intentions to subclassify in order to promote equitable justice were legitimate.
Defects in Law / Criticism:
- However, this case raises the possibility of abuse because Chinnaiah (2005) established a strict interpretation that all SCs must be handled identically, despite the enormous differences among them:
- Caste classification has been politicized for electoral purposes.
- No consistent standard or mechanism was provided in this situation to indicate how such sub-classification should be applied properly.
- Instead, there are inconsistencies among States, as each State may adopt alternative sub-classification criteria.
- Confusion and a delay in the implementation of the policy may result from the Court’s partial resolution of the matter, which left it up to a larger bench.
Inference:
- The historic ruling in State of Punjab v. Davinder Singh[2] reignites the discussion of the fair allocation of reservations among Scheduled Castes.
- A larger Constitutional bench will decide whether sub-classification is legal in the end, but the ruling is progressive in that it ensures that reservation actually reaches those in need.
- It marks a shift in judicial thinking from formal equality to substantive equality.
- It challenges the strict framework established in Chinnaiah and leans towards a more flexible, pragmatic approach to social justice.
Related Case Laws:
- E.V. Chinnaiah Vs State of Andhra Pradesh[3] (2005) 1 SCC 394
Held: States cannot subdivide Scheduled Castes (SCs) for the purposes of reservation because they are a homogeneous group.
Relevance: In Davinder Singh, this case was sent for reconsideration.
- Indra Sawhney Vs Union of India [4](Mandal commission case) 1992
Held: Reservation in promotions was prohibited (later reversed in some areas); sub-classification within OBCs is permitted based on relative backwardness.
Significance: Established a basis for logical categorization among disadvantaged groups.
- M. Nagaraj Vs Union of India[5]
Held: Before allowing SC/STs to be given preference in promotions, states must provide measurable evidence of their backwardness, insufficiency, and influence on efficiency.
Relevance: highlighted data-driven reservations, which had an impact on Davinder Singh’s policy foundation.
Case Comment:
Overview:
A major constitutional dispute about the extent and framework of caste-based reservations in India was reignited by the Supreme Court’s decision in State of Punjab v. Davinder Singh. In order to guarantee true equality and justice, the case contends that internal stratification within Scheduled Castes (SCs) calls for sub-classification, challenging the notion that SCs constitute a homogenous group. The reasoning behind the ruling, its legal ramifications, and its sociopolitical ramifications are all severely examined in this comment.
Background Information and Legal Context:
In order to guarantee that the most socially and educationally disadvantaged SCs received proportionate benefits from reservations in public employment and education, the State of Punjab attempted to sub-classify them. This led to the case. Citing the Supreme Court’s previous decision in E.V. Chinnaiah v. State of Andhra Pradesh [(2005) 1 SCC 394], which concluded that any sub-classification within SCs violates Article 341 of the Constitution, the Punjab and Haryana High Court ruled that this was unconstitutional. In Davinder Singh, the Supreme Court decided to deviate from Chinnaiah and refer the case to a bigger bench for review after the Punjab Government filed an appeal.
Evaluation of the Decision:
1.Understanding of Inequality Within:
The Court recognized that dominant castes within the SC group have largely monopolized the benefits of reservation, leaving marginalized sub-castes underrepresented. In order to move the conversation from nominal equality to substantive equality, this acknowledgment is essential. “Equality is more than just treating people equally.”
2. Distinguishing Welfare Measures from Article 341:
The Court explained that: • The State may take affirmative action to subclassify in order to ensure a fair distribution of benefits,Article 341 exclusively addresses the recognition and notification of SCs. Therefore, the constitutional list of SCs is unaffected by legislative purpose to address internal inequities. “Equality is not merely about treating equals equally but
3. Articles 14, 15(4), and 16(4) are highlighted:
Article 14 (Right to Equality), Article 15(4) (Special provisions for socially and educationally backward classes), and Article 16(4) (Reservation in public employment) are the three main sources of support for the decision. According to the Court, these Articles not only allow for but also require reasonable classification for social justice.
Implications:
• Legal Impact: Allows a broader bench to revisit Chinnaiah, potentially redefining reservation jurisprudence.
• Implications for Policy: Encourages states to carry out empirical research in order to identify castes that are considered backward within SCs and adjust quotas appropriately.
• Social Impact: Acknowledges that vulnerable people face compounded deprivation.
In conclusion:
- A-progressive interpretation of equality—not just sameness, but fairness based on context and need—is reflected in the Supreme Court’s ruling in the Davinder Singh case. By questioning the presumption of homogeneity within Scheduled Castes, it represents a watershed in reservation law. Though encouraging, the legal position is still precarious until the matter is resolved by a bigger Constitutional Bench.
- To develop a fair and inclusive framework that guarantees genuine social justice for all segments of marginalized groups, it will be imperative that the legislative and the court collaborate going forward.
- In this case, the Supreme Court considered whether states could subdivide Scheduled Castes in order to guarantee reservation benefits to the most disadvantaged members. The previous E.V. Chinnaiah (2005) decision, which maintained that SCs constitute a cohesive group and cannot be subdivided, was rejected by the Court. Because a few dominating castes within the SC list shouldn’t be able to monopolize reservation benefits, the bench ruled that sub-classification is constitutionally acceptable in order to achieve actual and substantive equality.
- The Court underlined that state powers under Articles 15(4) and 16(4) to advance social justice are distinct from Article 341, which gives the President the authority to notify SCs. The ruling was important because it permitted intra-group equity in reservations, but it also sent the case to a higher bench for a final decision.
- By emphasizing equality among underprivileged groups, the case represents a progressive change in reservation legislation; nonetheless, clarification will come from a wider Constitutional bench.
[1] State of Punjab v. Davinder Singh, (2020) 8 S.C.C. 1 (India).
https://indiankanoon.org/doc/2178030
[2]State of Punjab v. Davinder Singh, (2020) 8 S.C.C. 1 (India) https://indiankanoon.org/doc/2178030/
[2]
[3] E.V. Chinnaiah v. State of A.P., (2005) 1 S.C.C. 394 (India). https://indiankanoon.org/doc/1764064/
[4]Indra Sawhney v. Union of India, 1992 Supp. (3) S.C.C. 217 (India)
https://indiankanoon.org/doc/1363234/[4]
[5] M. Nagaraj v. Union of India, (2006) 8 S.C.C. 212 (India). https://indiankanoon.org/doc/1643304/