Author: Tanya Verma, Indore Institution of Law
Abstract
The Supreme Court’s decision in State of Punjab v. Davinder Singh (2024) marks a major shift in India’s reservation jurisprudence by permitting States to create sub-groups within the Scheduled Caste category for more precise distribution of benefits. The judgment rejects the earlier view that SCs must be treated as a single, indivisible class and instead recognizes significant socio-economic differences among sub-castes that influence access to opportunities. By grounding its reasoning in substantive equality under Articles 15 and 16, the Court affirms that affirmative action must reach those who remain most disadvantaged rather than those who have already advanced within the larger community. This abstract examines the constitutional principles invoked, the reasoning that led to the overruling of E.V. Chinnaiah, and the potential implications for policy design and social justice. While the ruling expands the flexibility of States to tailor reservation systems, it also raises questions about consistent criteria, administrative feasibility, and the risk of political misuse. Overall, the judgment represents a move toward a more refined and evidence-based approach to affirmative action in India.
Introduction
The case State of Punjab v. Davinder Singh (2024) stands as a significant moment in India’s constitutional debate on reservations. At its core, the dispute concerned whether States are permitted to create sub-categories within the Scheduled Caste community to ensure that reservation benefits reach groups that remain severely marginalized. Earlier rulings had treated the SC list as a single, uniform class, leaving little room to address disparities within it. In this judgment, a seven-judge bench reconsidered that position, acknowledging that social and educational backwardness is not evenly distributed across all SC communities. By allowing targeted sub-classification, the Court reopened foundational questions about equality, the purpose of affirmative action, and the evolving role of States in tailoring policies to local realities. This decision has since become a central reference point in discussions surrounding more nuanced and data-driven reservation frameworks in India.
Issues of the case
· Can the State subdivide the Scheduled Caste category for reservation?
· Does creating sub-quotas interfere with the Presidential List under Article 341?
· Is internal classification within SCs consistent with the right to equality under Article 14?
· Do Articles 15(4) and 16(4) allow the State to refine reservation policies inside the SC category?
Judgement
The seven-judge bench headed by Chief Justice D.Y. Chandrachud, delivered its judgement on 1 August 2024, with a 6:1 majority after hearing arguments for three days. The majority opinion, authored by Chandrachud held that the sub-classification of Schedule Castes and Scheduled Tribes is constitutionally permissible. Justices B. R. Gavai, Vikram Nath, Pankaj Mithal, Manoj Misra, and Satish Chandra Sharma wrote separate, concurring opinions.
Final Decision — What the Court Held
● By a majority of 6:1, the Court held that sub-classification within the Scheduled Castes (SCs) and Scheduled Tribes (STs) for the purpose of reservation is constitutionally permissible.
● The earlier ruling in E.V. Chinnaiah v. State of Andhra Pradesh (2004/2005) which had prohibited such sub-classification on the ground that SCs/STs must remain a homogeneous class was overruled.
● The Court held that although the list of SCs/STs (under Article 341) cannot be altered by States that remains the prerogative of the President/Parliament States may, for implementation of reservation, create sub-groups within the SC/ST class, and allocate quotas to disadvantaged sub-groups.
● The majority opinion, authored by Chief Justice D.Y. Chandrachud (with concurrence from some other judges), emphasised that caste-based lists under Article 341 simply identify the broad class; sub-classification for reservation benefits does not change that identity but only how benefits are distributed.
● The Court also stressed that such sub-categorisation should be backed by empirical data i.e. States must assess which sub-castes are relatively more backward or underrepresented before dividing quotas.
Dissenting Opinion
● The sole dissent came from Justice Bela M. Trivedi.
● She argued that SCs/STs as notified under Article 341 are meant to be treated as a unified, homogeneous class; allowing sub-division or sub-classification by States would amount to “tinkering” with the Presidential list something only Parliament (via Article 341) can do.
● According to her dissent, permitting sub-classification would violate the constitutional design, be arbitrary, and potentially deprive certain sub-castes of their legitimate share in reservation benefits.
Legal Provision at Issue
Article 14
The challenge was that sub-classification within SCs might violate equality by creating unequal treatment among groups within SCs. The Court had to examine whether such internal classification is permissible under “equality.”
Article 15(4)
Provides constitutional basis for affirmative action / reservation for SCs/STs/backward classes. Court asked whether subclassification qualifies under the “special provisions” allowed by Article 15(4).
Article 16(4)
This gives states power to provide reservations in public employment; Court examined whether this power can be used to create sub-categories within SC reservation.
Article 341
Opponents argued that list under Article 341 is exhaustive and SCs are a homogeneous class; any subclassification by state would amount to altering the “Presidential list.” The Court had to assess whether subclassification violates Article 341.
Conclusion
The Supreme Court upheld the validity of dividing the Scheduled Castes into sub-groups for reservation. It recognized that SCs are not uniform and that certain sub-communities may be more disadvantaged than others. The Court held that such subclassification promotes substantive equality and does not interfere with the Presidential List under Article 341. States are empowered under Articles 15(4) and 16(4) to design reservations that target the most socially and educationally backward groups, provided the policy is based on empirical data and can withstand judicial scrutiny. This ruling overruled the earlier Chinnaiah decision and allows for more precise implementation of social justice.
Important precedents
Indra Sawhney and Ors. v. Union of India and Ors.
E.V. Chinnaiah v. State of A.P. and Ors.
FAQs
Q.1 What was the main legal issue in the State of Punjab v Davinder Singh (2024) case?
The main legal issue in State of Punjab v. Davinder Singh (2024) was whether a State can create sub-categories within the Scheduled Castes (SCs) to give preferential reservation to the most backward groups among them, or whether all SCs must be treated as one single, indivisible class.
Q.2 What did the Supreme Court decide in this case?
The Supreme Court held that States are permitted to sub-classify Scheduled Castes and Scheduled Tribes so they can give priority in reservation to the most disadvantaged groups within them. This ruling overturned the earlier view that SCs/STs form a single, indivisible class.
Q.3 Why is this case significant for law students?
This case helps students understand how Constitutional provisions on equality and reservation (Article 14, 15, 16 & 341) are interpreted in modern India. It is a crucial precedent for understanding the balance between equality and affirmative action.
Q.4 How does this case impact future Government policies?
The case allows governments to create sub-quotas within SC/ST reservations, helping them target benefits to the most disadvantaged groups. This decision gives States greater flexibility in designing future reservation policies and may lead to new laws and revised quotas across India.
Q.5 What Constitutional principles can students learn from this judgement?
Students can study how the Doctrine of Reasonable Classification, Article 14’s equality principle and social justice philosophy are applied in real cases. It’s also a great example of judicial interpretation evolving with social needs.
