A) ABSTRACT / HEADNOTE

This case addresses the constitutional permissibility of subclassifying Scheduled Castes for affirmative action, including reservations under Articles 14, 15, and 16 of the Indian Constitution. The Supreme Court, by a majority, upheld the validity of such subclassification, overruling the precedent established in E.V. Chinnaiah v. State of Andhra Pradesh (2005). The Court held that Articles 15(4) and 16(4) permit subclassification for equitable allocation of benefits within the Scheduled Castes. The judgment clarified that Scheduled Castes do not form a homogeneous class and recognized historical and social heterogeneity among them. However, Justice Bela Trivedi dissented, asserting that any subclassification contravenes the constitutional framework under Article 341.

Keywords: Reservation, Scheduled Castes, Sub-classification, Intelligible Differentia, Affirmative Action.

B) CASE DETAILS

i) Judgement Cause Title:
The State of Punjab & Ors. v. Davinder Singh & Ors.

ii) Case Number:
Civil Appeal No. 2317 of 2011

iii) Judgement Date:
August 1, 2024

iv) Court:
Supreme Court of India

v) Quorum:
Dr. D.Y. Chandrachud, CJI; B.R. Gavai, Vikram Nath, Bela M. Trivedi, Pankaj Mithal, Manoj Misra, Satish Chandra Sharma, JJ.

vi) Author:
Dr. D.Y. Chandrachud, CJI

vii) Citation:
[2024] 8 S.C.R. 1321

viii) Legal Provisions Involved:
Articles 14, 15, 16, 341, and 142 of the Indian Constitution

ix) Judgments Overruled by the Case:
E.V. Chinnaiah v. State of Andhra Pradesh (2005) 1 SCC 394

x) Related Law Subjects:
Constitutional Law, Affirmative Action, Social Justice

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The genesis of this litigation lies in the State’s attempts to subclassify Scheduled Castes to address disparities within them. The High Court of Punjab & Haryana held such subclassification unconstitutional, citing the ruling in E.V. Chinnaiah. The appellants challenged this decision, arguing that E.V. Chinnaiah did not adequately consider the heterogeneity within Scheduled Castes.

D) FACTS OF THE CASE

The appellants, representing the State of Punjab, sought to implement policies for subclassifying Scheduled Castes to ensure equitable distribution of reservation benefits. They argued that a subset of Scheduled Castes had been historically marginalized even within the broader class. The respondents opposed the policy, contending it violated the constitutional protections afforded to Scheduled Castes under Article 341.

E) LEGAL ISSUES RAISED

1. Whether subclassification of Scheduled Castes for reservations is permissible under Articles 14, 15, and 16 of the Constitution.
2. Whether the Scheduled Castes constitute a homogeneous or heterogeneous group.
3. Whether Article 341 creates an immutable and indivisible class.
4. What are the limits on the scope of subclassification?

F) PETITIONER/APPELLANT’S ARGUMENTS

The appellants contended:

1. Subclassification is necessary to address the inequities within Scheduled Castes.
2. The principles of equality under Article 14 allow distinctions based on intelligible differentia.
3. Indra Sawhney v. Union of India permits subclassification within backward classes, and by extension, Scheduled Castes.
4. Article 341 does not preclude subclassification as long as it does not alter the Presidential List.

G) RESPONDENT’S ARGUMENTS

The respondents argued:

1. Subclassification violates the constitutional framework established under Article 341.
2. The decision in E.V. Chinnaiah categorically prohibits such subclassification.
3. The historical context of Scheduled Castes as a singular group necessitates equal treatment.
4. Subclassification is a legislative overreach and undermines the integrity of affirmative action policies.

H) JUDGMENT

a. Ratio Decidendi:
The Court upheld the validity of subclassification, reasoning that Scheduled Castes are socially heterogeneous and that subclassification ensures equitable distribution of benefits.

b. Obiter Dicta (If Any):
The judgment emphasized that empirical data and rational criteria are prerequisites for subclassification, warning against arbitrary or politically motivated policies.

c. Guidelines (If Any):

1. Subclassification must rely on quantifiable and demonstrable data.
2. The State must ensure subclassification aligns with the objectives of Articles 15(4) and 16(4).
3. Subclassification should not exclude any group entirely from the benefits of reservation.

I) CONCLUSION & COMMENTS

The judgment signifies a paradigm shift in the jurisprudence surrounding affirmative action, focusing on equitable representation within Scheduled Castes. While progressive, it underscores the need for meticulous policymaking grounded in empirical evidence.

J) REFERENCES

Important Cases Referred:

1. E.V. Chinnaiah v. State of Andhra Pradesh (2005) 1 SCC 394.
2. Indra Sawhney v. Union of India (1992) Supp 3 SCC 217.
3. State of Kerala v. N.M. Thomas (1976) 2 SCC 310.
4. M. Nagaraj v. Union of India (2006) 8 SCC 212.

Important Statutes Referred:

1. Constitution of India, Articles 14, 15, 16, 341, and 142.
2. Punjab Scheduled Castes and Backward Classes (Reservation in Services) Act, 2006.