Author: Drushti Jayesh Shah, Adv. Balasaheb Apte College of Law
To the Point
Reservations have consistently made headlines since their implementation in government jobs and education under Articles 15 and 16 of the Constitution of India. Over the decades, through various amendments and landmark case laws, the reservation policy has evolved significantly. In the landmark case of Indira Sawhney vs. UOI case, the Supreme Court of India established a 50% ceiling on reservations, preventing both the central and state governments from exceeding this limit in government jobs and educational institutions. Numerous important amendments have been introduced to modify these reservations. Most recently, on April 8, 2025, the Telangana government issued an official order to implement sub-categorization within Scheduled Castes (SCs), making it the first state in India to officially divide SCs into internal categories for reservation purposes in government jobs and education. This initiative can be viewed as a “reservation within a reservation” policy. The aim of this policy is to ensure that the most marginalized and backward individuals among SCs receive a greater share of opportunities in educational institutions and government jobs.
Abstract
On 8th April 2025 ,Telangana Government brought “Scheduled Caste ( Rationalisation of Reservation)Act 2025” which divided SCs into Internal categories for the purpose of Reservations in govt.jobs and education. This policy come after the Supreme court judgement on 1 august 2024 which permitted the state governments to make further sub division of SC and ST community for better benefits of reservation. Soon after the Judgement the Telangana government established a commission headed by the retired High court judges Shameem Akhtar. The purpose of this one man commission was to study on sub-classification within Scheduled Castes reserved categories and examine various facets of the social, economic, political and educational backwardness among sub groups and suggest the effective ways of implementation of sub-classification. Based on the recommendations of the commission the Scheduled Caste ( Rationalisation of Reservation) Act 2025 was introduced by the government. According to the recommendations 59 SC communities are divided into 3 grps
Group 1 – 15 most least developed communities are included in this group and 1℅ reservation has been given to them.
Group 2 – 11 moderately benefited communities are included in this group and 9% reservation has been given to them.
Group 3- 26 Significantly benefited communities are included in this group and 5 % reservation has been given to them.
This division sim to provide the least benefited, economical, social and educational backward communities more benefit and to make sure only few already upward communities does not take full benefits of Reservation. There were many complaints made to the state government that over the decades, some Sc communities have benefited more from reservation policy while other remained socially and economically backward. Taking this complaint into consideration and by the permit of supreme Court the teleagana government come with the act.
Legal Jargon
On 8 August 2024 , the supreme Court of India in review judgement of Punjab and Haryana High court delivered a landmark verdict allowing states authority to sub classify reserved category groups, such as schedule caste This is Overturned the 2004 judgement of E.V. Chinnaiah V. State of Andhra pradesh, altering the landscape of reservation policies in India. The Court ruled that states are constitutionally allowed to Sub – classify SCs & STs based on varying levels of backness. The Seven Judge Bench stated that State can Classify SCs within the 15%. Under Article 341 & Article 342, the president has the power to specify Castes, races or tribes as Scheduled Caste & Schedule tribes via public Notification. The supreme court in its ruling also Clarified that State governments are not restricted to further classify the communities of schedule Caste and tribes into sub- Caste for more benefits of Communities. Article 15(4), and 16 (4) allows both Union & state government to provide special provisions for the advancement of” Socially and educationally backward classes including SCs. Telangana using these provisions has rationalized the 15℅ SCs Quato, and has not increase it but reallocated it in more fairly among sub- groups to provide more benefits to the most disadvantaged groups for purpose of reservation.
Case Laws
1. E. V. Chinnaiah V. State of Andhra pradesh (2004)
This case addressed the issue of sub-classification within Scheduled Castes (SCs) for reservation purposes. The State of Andhra Pradesh categorize SCs into distinct sub-groups and assign reservation percentages accordingly. However, the Supreme Court declared such sub-classification as unconstitutional. The Court determined that SCs constitute a single, homogeneous class as recognized by the President under Article 341 of the Constitution. The court stated that no State possesses the authority to create sub-groups within this classification for differential treatment in reservations. The Court underscored that all SCs, regardless of their internal backwardness, are entitled to equal treatment under reservation policies. Any attempt at sub-division would infringe upon Articles 14, 15, and 16 of the Constitution.
2. State of Punjab V. Davinder Singh ( 2024)
This case represents a notable transformation in India’s reservation jurisprudence. A seven-judge Constitution Bench of the Supreme Court in review appeal set aside the previous judgement of E.V. Chinnaiah v. State of Andhra Pradesh (2004), declaring that Scheduled Castes (SCs) do not constitute a homogeneous group. The Court affirmed that sub-classification among SCs for the purpose of reservations is constitutionally permissible. This judgment empowers states to customize reservation policies more effectively, ensuring that resources and benefits reach the most disadvantaged sub-groups within the overall Scheduled Caste category.
Conclusion
Telangana’s reservation policy demonstrates the state’s dedication to achieving social justice and fostering inclusive development by addressing the historical disadvantages experienced by various marginalized communities. This policy could serve as a blueprint for other states looking to implement similar initiatives aimed at uplifting backward communities.
On one hand, some argue that reservations discriminate against those who deserve admission to educational institutions and government jobs based solely on merit. On the other hand, even after 75 years of independence, many backward communities have yet to benefit. Thus, reservations are essential, but they must be implemented with a well-structured policy to ensure that genuinely economically and socially disadvantaged communities receive the support they need, rather than those who are already uplifted. Telangana, along with other governments seeking to adopt such policies, should ensure that their initiatives are grounded in empirical data, uphold the principles of equality, and balance social upliftment with constitutional integrity.
FAQs
Q1: What is reservation?
Ans : Reservation is a policy that gives disadvantaged groups access to education, jobs, and representation to promote social equality.
Q. 2: Do State have power to implement Reservation?
Under Article 15(4) and Article 16(4) state gets the power to implement reservation in Educational institutions and Government Jobs.
Q. 3: What Percentage Reservation is given to SCs, STs and OBCs?
The reservation for SCs is 15℅, STs is 7.5℅, OBCs is 27℅.
Q.4: How are SCs ans STs classified?
By Article 341 and 342 president has the power to classify communities in SCS and STs.
