A) ABSTRACT / HEADNOTE

This case focuses on whether individuals who joined public-sector employment based on caste certificates issued by the State of Karnataka—later invalidated following de-scheduling of castes—can retain their positions. The Supreme Court assessed the validity of actions against employees and the protective measures adopted via government circulars. It clarified that only Parliament can modify Scheduled Castes or Tribes lists under Articles 341 and 342 of the Constitution. The judgment quashes termination notices, safeguarding employees under state and central circulars protecting those employed based on earlier caste certificates. The Court emphasized equitable enforcement of laws without prejudice.

Keywords: Scheduled Castes, caste de-scheduling, Articles 341 and 342, employment protection, Karnataka circulars.

B) CASE DETAILS

• i) Judgment Cause Title: K. Nirmala & Ors. v. Canara Bank & Anr.
• ii) Case Number: Civil Appeal Nos. 9916–9920 of 2024
• iii) Judgment Date: 28 August 2024
• iv) Court: Supreme Court of India
• v) Quorum: Hon’ble Justice Hima Kohli and Hon’ble Justice Sandeep Mehta
• vi) Author: Justice Sandeep Mehta
• vii) Citation: [2024] 8 S.C.R. 868 : 2024 INSC 634
• viii) Legal Provisions Involved: Articles 341, 342 of the Indian Constitution
• ix) Judgments Overruled by the Case: None mentioned
• x) Case Related to: Constitutional Law, Service Law

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The dispute emerged from the de-scheduling of certain castes in Karnataka, previously designated as Scheduled Castes (SC). Employees hired based on now-invalid caste certificates faced job terminations. This raised constitutional questions regarding jurisdiction over amendments to caste lists and the protection afforded to employees under earlier, lawful certificates.

D) FACTS OF THE CASE

• The appellants were employees of public-sector entities, including Canara Bank, hired under the SC quota based on caste certificates issued under Karnataka’s circulars.
• Karnataka’s government de-scheduled certain castes following State of Maharashtra v. Milind [2001 1 SCC 4], which held that only Parliament could amend SC/ST lists.
• Circulars from 2002 and 2003 protected existing employees but not future benefits based on caste status.
• Employers initiated termination notices, asserting the invalidity of the original caste certificates.
• Writ petitions challenging these notices were dismissed by the Karnataka High Court, prompting the present appeal.

E) LEGAL ISSUES RAISED

• i) Can employees retain their positions based on earlier-issued but now-invalid caste certificates?
• ii) Does the State have jurisdiction to modify SC/ST lists under Articles 341 and 342?
• iii) Are protective circulars issued by Karnataka valid under constitutional law?

F) PETITIONER/APPELLANT’S ARGUMENTS

• The appellants argued that their caste certificates were validly issued based on prevailing state notifications.
• They emphasized that de-scheduling should not retroactively affect their employment.
• Protection granted under Karnataka’s 2003 circular and the 2005 Ministry of Finance communication safeguarded their jobs as general category employees.
• They highlighted that no fraud or misrepresentation was involved in securing employment.

G) RESPONDENT’S ARGUMENTS

• Respondents contended the certificates were invalid from inception as Karnataka lacked authority under Articles 341 and 342 to amend SC/ST lists.
• They argued that benefits of Karnataka’s circulars were limited to state employees, excluding central entities.
• They invoked Milind, asserting that employment based on invalid certificates amounted to wrongful gain.

H) JUDGMENT

a. Ratio Decidendi:

• The Supreme Court held that Milind prohibits state governments from altering SC/ST lists. However, protection for existing employees is permissible under equitable principles.

b. Obiter Dicta:

• The Court noted the importance of balancing strict constitutional provisions with social equity in governance.

c. Guidelines:

• Employees with invalid certificates but hired lawfully under previous notifications retain their jobs as unreserved category employees.
• Termination notices were quashed.
• Future benefits based on caste status were disallowed.

I) CONCLUSION & COMMENTS

This judgment reaffirms Parliament’s exclusive power over SC/ST lists while ensuring fair treatment for employees caught in administrative lapses. The Court balanced legal compliance with principles of fairness and equity.

J) REFERENCES

a. Important Cases Referred:

1. State of Maharashtra v. Milind, [2001] 1 SCC 4
2. Chairman and Managing Director, Food Corporation of India v. Jagadish Balaram Bahira, [2017] 8 SCC 670

b. Important Statutes Referred:

1. Constitution of India, Articles 341, 342