Supreme Court Ruling on Sub-Classification of SCs and STs

Indian Polity Judgments and Directives

03-Aug-25

Context

On August 1, 2024, the Supreme Court, in State of Punjab & Ors vs Davinder Singh & Ors, ruled that states are empowered to sub-classify Scheduled Castes (SCs) and Scheduled Tribes (STs) to ensure equitable distribution of reservation benefits among the most disadvantaged sub-groups.

Background & Timeline

Year/Case	Development
2005 – EV Chinnaiah Case	SC held that SCs form a homogeneous class under Article 341(1) and cannot be sub-divided.
2006 – Punjab Act	Reserved 50% of SC quota in recruitment for Balmikis and Mazhabi Sikhs.
2010 – HC Verdict	Struck down the provision, citing Chinnaiah.
2020 – Davinder Singh Case	Five-judge bench referred issue of sub-classification to a larger bench.
2024 – Final Verdict	Seven-judge bench allows state-wise sub-categorisation of SCs and STs.

Key Supreme Court Ruling (2024)

Sub-categorization Permitted: States may create sub-quotas within SC/ST lists.
‘Creamy Layer’ to be Excluded: Reservation benefits should bypass relatively privileged SC/ST sections.
Empirical Backing Needed: Sub-classification must be based on socio-economic data and is open to judicial review.
Article 14 Not Violated: Sub-categorization upholds equality; does not infringe the President’s powers under Article 341.

Constitutional Provisions Involved

Article	Provision
Article 15(4)	Special provisions for socially and educationally backward classes.
Article 16(4)	Reservation in public employment for underrepresented groups.
Article 341(1)	President notifies SCs for each state.
Article 342(1)	Similar provision for STs.

Why Sub-Categorization Is Necessary

Intra-Group Disparities:
Example: Madigas in Telangana (50% of SC population) allege underrepresentation due to dominance of Malas.
Equitable Distribution:
Prevents concentration of benefits among dominant sub-castes.
Localized Affirmative Action:
Empowers states to tailor policies to regional disparities.
Social Mobility & Inclusion:
Helps reach most backward sections through targeted welfare.

Challenges in Sub-Categorization

?? Data Scarcity: Lack of granular socio-economic data.
?? Federal Tensions: Ambiguity on whether states can redefine or sub-classify SCs.
?? Risk of Division: May fracture community unity and lead to internal rivalry.
?? Complex Criteria: Defining ‘backwardness’ uniformly across states is difficult.

Suggestions & Way Forward

Wider Interpretation of Article 341: Sub-classification doesn’t alter original SC list—only allocates benefits within it.
Apply Creamy Layer Test (Contextually): Consider education, income, occupation.
Transparent & Empirical Approach: Base decisions on reliable, disaggregated data.
Legal Backing: Constitutional amendment (as suggested by Usha Mehra Committee) could formalize state power.
Middle Path: Combine group identity with intra-group justice to avoid fragmentation.

Key Committee Recommendations

Justice P. Ramachandra Raju Commission (1996): Recommended SC sub-categorization in Andhra Pradesh.
Usha Mehra Committee (2008): Proposed adding Clause (3) to Article 341 to empower state legislatures.
NCSC & NCST: Advocated intra-group equity in distributing benefits.
Justice G. Rohini Commission (2023): Submitted report on OBC sub-categorisation, relevant for SC/ST framework.

Conclusion

The SC’s 2024 ruling is a landmark shift in affirmative action, recognizing that SCs and STs are not monolithic. Sub-categorization ensures that reservation reaches the most disadvantaged, making social justice more equitable and inclusive. However, it must be executed with constitutional caution, empirical evidence, and community sensitivity.

Source: Indian Express

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