In State of Punjab v. Davinder Singh (2024), a 7-judge Constitution Bench of the Supreme Court upheld that States can sub-classify Scheduled Castes for equitable distribution of reservation benefits, overruling the 2004 E.V. Chinnaiah judgment.
Constitutional Basis:
- Article 14: Guarantees equality before the law; permits reasonable classification.
- Article 16(1): Ensures equal opportunity in public employment.
- Article 16(4): Allows reservation for backward classes not adequately represented.
- Article 15(4): Permits special provisions for socially & educationally backward classes.
- Article 341(1): The President notifies SCs for each state.
- Article 341(2): Only Parliament can modify the SC list.
Key Judicial Rulings:
- E.V. Chinnaiah v. State of A.P. (2005)- Held SCs are a homogeneous group; sub-classification by states violates Article 341.
- State of Punjab v. Davinder Singh (2024)-
- Overruled Chinnaiah judgment; Supreme Court allowed States to sub-classify SCs under Articles 15(4) & 16(4).
- Held, this is a reasonable classification under Article 14.
- Does Not Violate Article 341: Clarified that sub-classification does not alter the SC list notified under Article 341(1); it only aims to rationalize the internal distribution of benefits.
- Affirms Article 14 & 16: Held that equality means treating unequals unequally, and sub-classification is a form of affirmative action to uplift the most backward within SCs.
- State’s Power Recognized: Emphasized that the State has legislative and executive competence to make such classifications based on data showing unequal access to benefits.
- Indra Sawhney v. Union of India (1992)-
- Recognized sub-classification within OBCs to prevent benefits from being monopolized.
- Though related to OBCs, it laid the conceptual foundation for sub-grouping in reservation policies.
- The Supreme Court interpreted Article 356 of the Constitution to define the contours of proclamation of President’s rule.
- The ruling stated that the President’s proclamation can be subject to judicial review on grounds such as illegality, malafide, extraneous considerations, abuse of power, or fraud.
- Parliamentary approval is now necessary for imposing President’s rule. Till then, the President can only suspend the state legislature. The ruling emphasized that states are not mere appendages of the Centre, setting a redline for center-state relationships.
- Laid down the supremacy of the floor test in determining the support enjoyed by the party in power.
- The use of Article 356 was justified only when there was a breakdown of constitutional machinery and not that of administrative machinery.
- Secularism is a part of the basic structure of the Constitution.
Extra:
- Based on the Sarkaria Commission report (1988), the SC in this case has enlisted where the use of the exercise of power under Article 356 could be proper or improper.
- It was invoked in recent cases challenging President’s rule in Uttarakhand (2016) and Arunachal Pradesh (2016).
