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.
