SC: State Can Sub-classify SCs and STs

On August 1st, 2024, in a landmark judgement the seven-judge bench of the Supreme Court of India ruled that state governments can sub-classify Scheduled Castes (SCs) and Scheduled Tribes (STs) for reservation purposes, overturning the previous E.V. Chinnaiah judgement that had deemed such sub-classification impermissible.

Key Points

Besides CJI Chandrachud, other judges on the bench were Justices BR Gavai, Vikram Nath, Bela M Trivedi, Pankaj Mithal, Manoj Misra, and Satish Chandra Sharma.
The court emphasized that while sub-classification is allowed, states must base their decisions on empirical data demonstrating inadequate representation and differing levels of social backwardness among the groups.
The court opined that Article 14 of the Constitution permits sub-classification of a class that is not similarly situated for the purpose of the law.
The court clarified that sub-classification would not violate Article 341(2) as long as it doesn’t provide exclusive benefits to certain castes over all reserved seats.
The Constitution does not bar the allocation of a percentage of seats to a caste since every caste is a class. However, the state must have sufficient material to prove inter-se backwardness between each of the castes.
The state must, with the submission of cogent material, prove that there is a rationale principle that distinguishes the groups included and those excluded from the class.

Article 14 of Constitution of India

Article 14: The State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India. It states that no one is above the law of the land and the Rule of Law shall prevail as all are equal in the eyes of law. But this rule is not absolute and is subject to many exceptions.

Doctrine of Reasonable Classification

The State has the authority to create laws that apply differently to various classes of people, while still adhering to the principle of equality of civil rights and equal protection under the law. This concept is known as the 'Doctrine of Reasonable Classification.'