Author -Geeta Shinde, Manikchand Pahade law college Ch.Sambhajinagar
To the Point
This is one most important landmark case and it’s judgement in India State of Punjab. Vs Davinder Singh.This case judgement is given in year 2024, the Supreme Court of India upheld the constitutional validity of sub-classification within the Scheduled Castes (SC) category for the purpose of providing reservations in services.
The Supreme Courts 7 judges banch is selected for deciding The case State of Punjab vs Davinder Singh , This banch of judges reevaluated the initial judgement given in case of F.V.Chinnaiah Vs State of Andhrapradesh
(2005) . As reconsider that decision which had declared such sub-classification is unconstitutional. The Courts decision is greatly affect policies that aim to help disadvantaged groups and how we understand the Indian constitutions Articles about Equality – Article 14, 15 and 16.
The Proof
In case of State of Punjab Vs. Davinder Singh ,The Supreme Court’s decision was based on a thorough , deep analysis and examination of constitutional provisions, judicial precedents, and empirical data. The Court found that the Scheduled Castes are not a homogeneous group and that certain sub-groups within the SC category are more disadvantaged than others. This empirical, experience basis justification that need for sub-classification to ensure that the benefits of reservations reach the most backward sections within the SCs. The Court also emphasized that sub-classification does not alter the Presidential list under Article 341 but is a measure to distribute benefits more equitably within the existing SC list.
Abstract
The State of Punjab v. Davinder Singh case addresses the constitutionality of sub-classifying Scheduled Castes for the purpose of reservations in services. The Supreme Court oversee the past decision in E.V. Chinnaiah Vs State of Andhrapradesh and held that sub-classification is permissible under Articles 14, 15(4), and 16(4) of the Constitution. The Court’s ruling is grounded in the principle of substantive equality, recognizing the varying degrees of backwardness within the SC category and the necessity to address these disparities through affirmative and positive action.
Case Laws
E.V. Chinnaiah v. State of Andhra Pradesh (2005) : This case held that sub-classification within the Scheduled Castes is unconstitutional, treating the SCs as a homogeneous group.
Indra Sawhney v. Union of India (1992) : The Court permitted sub-classification within Other Backward Classes (OBCs) for the purpose of reservations, emphasizing the need for affirmative action to address varying degrees of backwardness.
State of Punjab v. Davinder Singh (2024) : The Supreme Court overruled Chinnaiah and upheld the constitutionality of sub-classification within the SC category, aligning with the principles established in Indra Sawhney.
Conclusion
The State of Punjab v. Davinder Singh judgment mark out a critical moment in the evolution of affirmative action in India. By recognizing the heterogeneity within the Scheduled Castes and permitting sub-classification, the Supreme Court has reinforced the principle of substantive equality. This decision allows states to tailor their reservation policies to address the specific needs of the most disadvantaged sub-groups within the SC category, thereby promoting a more equitable distribution of opportunities.
FAQs
What is sub-classification within Scheduled Castes?
Sub-classification refers to the practice of dividing the Scheduled Castes into smaller groups based on varying degrees of backwardness of people in SC category. to confirm that the benefits of reservations are distributed more equitably among SC category people.
Why was the E.V. Chinnaiah judgment overruled?
The Supreme Court overruled the E.V. Chinnaiah Vs State of Andhrapradesh. judgment because it treated the Scheduled Castes as a homogeneous group, disregarding the varying degrees of backwardness within them. The Court found that sub-classification is necessary to achieve substantive equality.
How does this judgment impact affirmative action policies?
This judgment allows states to implement more nuanced affirmative action policies by recognizing the internal diversity within the Scheduled Castes, thereby ensuring that the most disadvantaged groups benefit from reservations.
Does this decision affect the Presidential list under Article 341?
No, the Supreme Court clarified that sub-classification does not alter the Presidential list under Article 341 but is a measure to distribute benefits more equitably within the existing SC list.
Can other states implement sub-classification based on this judgment?
Yes, other states can implement sub-classification within the Scheduled Castes for Punjab the purpose of reservations, provided they have empirical data to justify the need for such classification and ensure that it aligns with the principles laid down in this judgment .
