Syllabus: GS2/Polity and Governance
Context
- The Telangana government has notified the implementation of the Telangana Scheduled Castes (Rationalisation of Reservations) Act 2025 for categorisation of Scheduled Castes (SC) into three groups.
About
- Telangana has become the first Stateto operationalise the classification of the Scheduled Castes after the Supreme Court’s landmark judgment.
- The judgement upheld the constitutionality of sub-classifying the SCs and Scheduled Tribes (STs) to grant separate quotas for the most marginalised groups within these communities.
- Methodology Used for Categorisation: As per the SC’s verdict, empirical data, social, economic, educational, employment and political status of the SC communities was considered.
- Categorisation: 59 SC communities in the state will be divided into three categories – Group I, II and III.
- Group I: 15 sub-castes categorised as most backward have been classified as Group-I with 1 per cent reservation, these groups constitute just 0.5% of the population.
- Group II: 18 sub-castes of the total 59 which received marginal benefits have been placed under Group-II with 9 per cent reservation.
- Group III: 26 sub-castes that were relatively better placed in Group III in terms of opportunities with 5 per cent reservation.
| About SC/ST Reservation – Article 341 of the Constitution empowers the President to designate certain ‘castes, races, or tribes’ as SCs based on historical injustice. – According to Census 2011, Schedule Castes (SCs) approximately 16.6%, and Schedule Tribes (STs) approximately 8.6% of India’s population. 1. SC groups collectively receive 15% reservation in education and public employment. 2. Over time, some SC groups have been underrepresented compared to others. 3. States have attempted to extend additional protection to these marginalised groups, but such efforts faced judicial scrutiny. Related Constitutional Provisions – Article 14: Guarantees equality before law. – Article 15 (4): The state is empowered to make any special provision for the advancement of any socially and educationally backward classes of citizens or for the scheduled castes. – Article 16(4), 16 (4A) and 16 (4B): Provide for reservation in posts and services. – Article 335: Mentions maintaining administrative efficiency while considering SC/ST claims in public employment. |
Supreme Court’s Judgement in State of Punjab v Davinder Singh case (2024)
- In the 2024 State of Punjab v Davinder Singh case, a seven-judge bench upheld the constitutional validity of sub-classification within SC/ST categories.
- This judgment has overruled the earlier decision in the EV Chinnaiah v. State of Andhra Pradesh case (2004), which held that ‘Scheduled Castes’ notified under Article 341 form one homogeneous group and that sub-categorization is not permissible.
- Sub-classification within the Scheduled Castes does not violate Article 341(2) because the castes are not per se included in or excluded from the List.
- Historical and empirical evidence demonstrates that Scheduled Castes are a socially heterogeneous class. Thus, the State, in the exercise of its power under Articles 15(4) and 16(4), can further classify Scheduled Castes if (a) there is a rational principle for differentiation; and (b) the rational principle has a nexus with the purpose of sub-classification.
Arguments in Favour
- Unequal Backwardness Within SCs: Some castes within the SC communities are more socially and educationally backward than others and have been consistently underrepresented.
- Treating unequals equally perpetuates inequality, defeating the purpose of reservation.
- Constitutional Mandate allows it: Articles 15(4) and 16(4) empower the state to make special provisions for the advancement of any socially and educationally backward class.
- Promotes Effective Representation, Not Just Numerical: The goal is effective representation, not mere numbers, sub-classification can help achieve meaningful inclusion.
- Backed by Empirical Data: Allows the government to target affirmative action where it’s needed the most.
Arguments Against
- Article 341: Article 341 allows only the President to modify the SC list.
- State-led sub-classification is seen as indirect interference with the list and beyond state powers.
- Fragmentation Within Community: Sub-quotas can lead to increased caste-based divisions among SCs.
- It may undermine collective political strength and social solidarity of SC communities.
- Defining Criteria: Establishing objective, empirical measures of disadvantage within SCs is challenging.
- Risk of inaccurate classification and legal challenges.
- Opens the ‘Creamy Layer’ Debate: Introducing the ‘creamy layer’ concept for SCs (as some judges suggest) could dilute the protection provided to SCs as a whole.
- Reservation for SCs is not just about economic backwardness, but historical discrimination and stigma, which persists across income groups.
Way Ahead
- States can now create sub-quotas within SC/ST reservations.
- It gives greater autonomy for states to address internal disparities within the SC/ST groups.
- However, stringent requirements of evidence and data may make implementation complex.
Source: TH
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