Author: Saleha Haneef, a student at Integral University, Lucknow
CASE NAME: E.V. CHINNAIAH V. STATE OF ANDHRA PRADESH (2004)
CASE NO.: Appeal (civil) 6758 of 2000
PETITIONER: E.V. CHINNAIAH
RESPONDENT: STATE OF ANDHRA PRADESH & ORS.
JUDGES: D.Y. CHANDRACHUD CJI, VIKRAM NATH J, B.M. TRIVEDI J, PANKAJ MITHAL J, B.R. GAVAI J, S.C. SHARMA J, MANOJ MISRA J
ABSTRACT
E.V. Chinnaiah v. State of Andhra Pradesh was a Supreme Court case that resulted in 6:1 majority ruling in favour of allowing states to sub-classify Scheduled Castes (SC) and Scheduled Tribes (ST) for reservation purposes. In the original 2004 ruling, a five-judge bench held that SCs were a homogeneous class and could not be sub-classified for reservation purposes. The ruling also stated that sub- classification would violate Article 14 of the Constitution. In a 2024 judgment, a seven-judge bench headed by Chief Justice D.Y. Chandrachud reversed the 2004 decision, ruling that states have the constitutional authority to sub-classify Scheduled Castes (SCs) and Scheduled Tribes (STs) to uplift those castes that are more socially and educationally disadvantaged.
INTRODUCTION
The Indian Constitution, under Article 16(4), empowers the state to make special provisions for the advancement of socially and educationally backward classes of citizens, including SCs and STs. Reservation policies, aimed at ensuring equitable access to education and employment, are a cornerstone of these special provisions. However, the question of whether these reserved categories can be further sub-classified for the purpose of reservations has been a subject of intense legal and political debate.
The 2004 E.V. Chinnaiah judgment held that SCs constitute a homogeneous group and cannot be further sub-classified for reservation purposes. The Court reasoned that such sub-classification would violate the principle of equality enshrined in Article 14 of the Constitution. This judgment had a significant impact on reservation policies across the country, restricting the ability of states to implement more targeted interventions within the SC/ST categories.
ARGUMENTS BY THE PETITIONER
- Ensuring Adequate Representation:
The petitioners contended that sub-classification was essential to ensure sufficient representation for the most disadvantaged segments within the SC category. They highlighted the differing degrees of backwardness among the groups and how various castes experienced distinct levels of discrimination based on their professions. This variation, they claimed, called for sub-classification to guarantee that all groups gain from reservation policies.
- Flawed Reasoning in E.V. Chinnaiah:
The petitioners challenged the logic applied in the earlier E.V. Chinnaiah judgment. They argued that the court wrongly rejected the Andhra Pradesh government’s justification for sub-classification by citing the Indra Sawhney v. Union of India case. According to them, the Indra Sawhney judgment allowed sub-classification only for Other Backward Classes (OBCs), not SCs/STs, which was an irrelevant comparison.
- State’s Role in Assessing Backwardness:
The petitioners contended that state governments were best equipped to evaluate the extent of backwardness among communities at the local level. They pointed to the E.V. Chinnaiah and Davinder Singh cases, where both Andhra Pradesh and Punjab governments had enacted legislation creating quotas for specific castes within their respective SC groups. This, according to the petitioners, demonstrated the states’ capability to make informed decisions about sub-classification.
- Sub-Classification Doesn’t Alter the Presidential List:
The petitioners maintained that sub-classification did not violate the Constitution by creating or identifying new castes outside the presidential list. They argued that states were merely adjusting the distribution of existing resources within the SC category to ensure the most marginalized groups benefit more. They emphasized that the power to amend the presidential list remained with the President and Parliament, while states only facilitated a more equitable distribution of reservation benefits.
- Article 16(4) and “Adequate Representation”:
The petitioners highlighted the language in Article 16(4) of the Constitution, which allows the state to provide reservations for backward classes who are not “adequately represented” in government services. They argued that the emphasis on “adequately” rather than “equally” implied no obligation to provide identical opportunities to every caste within the presidential list. Furthermore, they asserted that Article 16(4) defined “state” to include all local governments, empowering them to implement sub-classification within their jurisdictions.
- Sub-Classification Similar to Creamy Layer:
The petitioners drew a parallel between sub-classification and the “creamy layer” principle established in the 2018 Jarnail Singh v. Lachhmi Narain Gupta case. Similar to how the creamy layer excludes the better-off sections from reservation benefits, sub-classification focuses on prioritizing the most disadvantaged castes within the SC category. This comparison, they argued, demonstrated that preferential treatment within the SC group could be implemented without violating the reservation system.
- Failure of Reasonable Classification Test in E.V. Chinnaiah:
The petitioners criticized the E.V. Chinnaiah judgment for not applying the “twin test” of reasonable classification before determining that sub-classification infringed upon Article 14 (equality). They argued that the court disregarded available social data that supported sub-classification, unlike the detailed data considered by the High Court in the same case.
ARGUMENTS BY THE RESPONDENT
- Homogeneity of Scheduled Castes:
Respondents argued that Article 341(1) of the Constitution, by grouping diverse castes into a single “Scheduled Class,” establishes a presumption of homogeneity. They emphasized that despite internal differences, SCs share a common history of discrimination and backwardness, as evidenced by their inclusion in the presidential list. The purpose of Article 341, according to respondents, is to address the collective discrimination and backwardness faced by the SCs as a whole, rather than focusing on individual caste-based disparities.
- Presidential Power and the Immutability of the List:
Respondents asserted that the President holds the sole authority to identify and include castes in the Scheduled Castes list under Article 341(2). They argued that any changes to the list, including the inclusion or exclusion of castes, must be made by Parliament. While state governments can provide input, they lack the independent authority to create sub-classifications within the SC category.
- Violation of Article 16(2):
Respondents contended that while SCs as a whole are recognized as a backward class under Article 16(4), individual castes within the SC list cannot be considered separate classes for the purpose of reservations. They argued that creating sub-classifications would violate Article 16(2) of the Constitution, which guarantees equality of opportunity in matters of public employment.
- Undermining the Purpose of Reservations:
Respondents argued that sub-classification would lead to fragmented and ineffective implementation of reservation policies. They asserted that focusing on specific sub-groups within SCs would undermine the overarching goal of uplifting the entire SC category as a whole.
JUDGMENT
In 2004, the Supreme Court determined that SCs form a unified group and cannot be further divided for the purposes of reservation. This ruling was grounded in the belief that such sub-classification would infringe upon the principle of equality as outlined in Article 14 of the Indian Constitution. However, in a noteworthy shift from the 2004 ruling, the Supreme Court recently dismissed the E.V. Chinnaiah decision. The Court acknowledged the inherent diversity within SC/ST communities and recognized the necessity for targeted measures to cater to the specific needs of the most marginalized segments within these categories. The Court concluded that sub-classification within reserved categories is allowed under Article 16(4) of the Constitution, as long as it is founded on identifiable criteria and aims to fulfill the goals of social justice and equality. The court observed that historical evidence indicates that SCs are not a uniform group. It also stated that states must substantiate sub-classification with empirical data demonstrating the underrepresentation of the sub-group.
According to the majority opinion of the bench, permitting the sub-categorization of scheduled castes in reservations will now facilitate broader protection for underrepresented groups. The comprehensive judgment in this case, spanning a total of 565 pages, comprises six separate concurring opinions. The majority opinion has overturned the 18-year-old E.V. Chinnaiah v. State of A.P., [(2004) 1 SCC 394] ruling, where a five-judge bench of the Supreme Court had determined that Scheduled Castes constitute a homogeneous class and that no subdivisions among them are allowed. The five-judge bench further asserted that such sub-classification of SC/STs contravenes Article 341 of the Constitution.
The current judgment in the case primarily examined two aspects during the proceedings:
- Should sub-classification within the reserved castes be permitted?
- The validity of the E.V. Chinnaiah ruling.
The Supreme Court has now reversed the E.V. Chinnaiah ruling and authorized sub-classification within the SCs in State Of Punjab & Ors. V Davinder Singh & Ors. This decision will have a significant impact on states striving to offer enhanced protection to specific castes that remain notably underrepresented despite reservations, in contrast to the more dominant scheduled castes. The court remarked that “historical and empirical evidence demonstrates that Scheduled Castes are not a uniform group.” It also clarified that while sub-classification is permitted, states cannot allocate 100% reservation to a sub-group. A safeguard has been introduced, requiring the state to justify sub-classification with empirical data show.
The following was determined by CJI Chandrachud and Justice Mishra in their ruling:
- Regarding the matter of sub-classification among the Scheduled Castes, it was concluded that further classification is permissible if:
(a) There exists a logical basis for differentiation
(b) The logical basis is connected to the objective of sub-classification
- Concerning the homogeneity of Scheduled Castes, this ruling established that Scheduled Castes cannot be considered a homogeneous integrated group, as sufficient empirical evidence suggests the presence of inequality within the Scheduled Castes themselves. The ruling also indicated that the inclusion of Scheduled Castes under Article 341 does not inherently lead to the establishment of a uniform and internally homogeneous class that cannot be further divided. The inclusion in Article 341 serves to identify Scheduled Castes by differentiating them from other groups.
- The ruling further stated that the State, in exercising its authority under Articles 15 and 16, has the freedom to recognize varying levels of social backwardness and to implement special measures (such as reservations) to address the specific degree of disadvantage identified. However, regarding the extent of the state’s authority on sub-classifying Scheduled Castes, the ruling maintained that the state’s sub-classification efforts must be based on quantifiable and demonstrable data related to levels of backwardness and representation within State services. The ruling emphasized that the State must demonstrate that the group or caste delineated from the broader Scheduled Castes is more disadvantaged and underrepresented. Additionally, the ruling clarified that any model that excludes certain Scheduled Castes from benefits will be deemed unconstitutional.
CONCLUSION
The overturning of the E.V. Chinnaiah ruling signifies a notable change in the comprehension and application of reservation policies in India. This recent reversal acknowledges the intrinsic diversity within SC/ST communities. The Court recognized that while SCs and STs are categories recognized by the Constitution, considerable socio-economic disparities persist within these groups. Certain sub-groups within these categories experience higher levels of marginalization and necessitate more focused interventions to address historical and systemic disadvantages. By permitting sub-classification within reserved categories, the Supreme Court has acknowledged the intricate realities of social and economic disparities within marginalized communities. This decision holds the potential to improve the efficacy of affirmative action programs and ensure that the advantages of reservation are directed towards the most deserving and marginalized segments of society.
FREQUENTLY ASKED QUESTIONS (FAQ)
- What was the main issue in the E.V. Chinnaiah case?
The main issue was whether the government could sub-classify Scheduled Castes (SCs) for the purpose of reservations.
- What was the outcome of the original 2004 E.V. Chinnaiah judgment?
The 2004 judgment held that sub-classification of SCs was unconstitutional as it violated Article 14 of the Constitution.
- Why was the 2004 E.V. Chinnaiah judgment overruled?
The recent judgment recognized the diverse socio-economic conditions within SC communities. The court acknowledged that some sub-groups within SCs face greater marginalization and require more targeted interventions. It was held that sub-classification within reserved categories is permissible under Article 16(4) of the Constitution.
