• In a landmark judgment, a seven-judge bench of the Supreme Court of India ruled by a 6-1 majority that the sub-classification of Scheduled Castes (SCs) is permissible to grant separate quotas for more backward sections within the SC categories.

Key Aspects of the Judgment

1. Sub-classification Permissibility:

• The Supreme Court bench, led by Chief Justice of India (CJI) D.Y. Chandrachud, held that sub-classification within SCs is allowed to ensure that the benefits of reservation reach the most backward sections within the SC category.
• The Court emphasized that such sub-classification must be based on empirical data that demonstrates the inadequacy of representation of the sub-class within the SC category.

2. Conditions and Limitations:

• The judgment clarified that while sub-classification is permissible, the State cannot earmark 100% reservation for a particular sub-class within the SCs. There must be a balance to ensure fair representation across the entire SC category.
• The State must justify the sub-classification with empirical data and evidence to show that a particular sub-class within the SCs is underrepresented and requires additional support.

3. Overruling of E.V. Chinnaiah Judgment:

• The bench overruled the 2004 judgment in E.V. Chinnaiah v. State of Andhra Pradesh, which had held that SCs notified under Article 341 form a homogenous group and cannot be sub-categorized.
• The majority opinion, including six concurring judgments, highlighted the need for a nuanced approach to reservation that addresses intra-category disparities.

4. Dissenting Opinion:

• Justice Bela Trivedi was the lone dissenter, holding that sub-classification within SCs is not permissible and that the SC category should remain homogenous as intended by the Constitution.

Implications for Reservation Policy

1. Targeted Affirmative Action:

• The ruling allows for more targeted affirmative action policies, enabling the State to direct benefits to the most deprived sections within the SC category. This can potentially enhance the effectiveness of the reservation policy by addressing intra-category disparities.

2. Empirical Data Requirement:

• The judgment underscores the importance of empirical data in justifying sub-classification. States will now need to conduct detailed studies and gather data to support any decision to sub-classify SCs for reservation purposes.

3. Balancing Act:

• By setting the condition that 100% reservation for a sub-class is not permissible, the Court has ensured that the overall balance and fairness of the reservation system are maintained. This prevents the creation of new inequities within the SC category.

Other Major Landmark Judgements of Supreme Court Related to Reservation