Don't Have an Account?
Art and Culture
01 May, 2025
SC Sub-Categorisation in Telangana
Wed 16 Apr, 2025
Context:
Telangana has made history by becoming the first Indian state to implement the sub-categorisation of Scheduled Castes (SCs) under the Telangana Scheduled Castes (Rationalisation of Reservations) Act, 2025. This action follows the Supreme Court’s recent 2024 judgment in State of Punjab v. Davinder Singh, which upheld the constitutionality of such sub-classifications within the SC and ST communities.
The Telangana SC Rationalisation Act seeks to divide the existing 15% SC reservation quota among three groups of SCs based on socio-economic and educational indicators. This is a significant departure from the “homogeneous” treatment of SCs in reservation policies thus far.
| Group | No. of Sub-Castes | SC Population % | Reservation % | Category Description |
| I | 15 | 3.29% | 1% | Most disadvantaged |
| II | 18 | 62.75% | 9% | Moderately benefitted |
| III | 16 | 33.96% | 5% | Significantly benefitted |
- This classification is based on the recommendations of the Shamim Akhtar Commission, which analysed over 8,600 community representations considering factors like education, employment, and access to government schemes.
Legal & Constitutional Framework
Several constitutional provisions support such rationalisation:
- Article 14 allows for reasonable classification, as long as there is a clear logic and connection to the objective.
- Article 15(4) & 15(5) permit special provisions for educational upliftment of backward communities.
- Article 16(4) empowers states to reserve jobs for inadequately represented backward classes.
- Articles 341(1) & (2) guide the identification and alteration of SC lists, where the final authority rests with the President and Parliament.
Earlier, the E.V. Chinnaiah v. State of Andhra Pradesh (2004) verdict had ruled against such sub-classifications. However, this has now been overruled by the 2024 Davinder Singh judgment, which gave states the liberty to sub-categorise SCs, provided it is supported by credible data and not political motives.
Debate: A Divided Discourse
| For Sub-Categorisation | Against Sub-Categorisation |
| Ensures equitable reservation access for the most deprived. | Risks dividing a historically united SC identity. |
| Prevents ‘creamy layer’ among SCs from monopolising benefits. | May be used for political gains and deepen caste lines. |
| Targets support through data-backed classification. | Could dilute the broader goals of social justice and collective voice. |
While the government argues this move addresses internal imbalances and promotes inclusive justice, critics fear it could fragment the Dalit solidarity that has long been central to their political mobilisation.
Major Reservation Judgements and Acts in India
| S. No. | Judgement/Act | Year | Key Provisions/Observations |
| 1 | Constitution (First Amendment) Act | 1951 | Added Article 15(4) allowing special provisions for advancement of backward classes. |
| 2 | Indra Sawhney v. Union of India (Mandal Commission Case) | 1992 | Upheld 27% reservation for OBCs; introduced the creamy layer concept; capped total reservation at 50%. |
| 3 | State of Kerala v. N.M. Thomas | 1976 | Held that Article 16(4) is not an exception to Article 16(1) but a facet of equality. |
| 4 | M. Nagaraj v. Union of India | 2006 | Allowed SC/ST promotions with reservation, but required proof of backwardness, inadequate representation, and impact on efficiency. |
| 5 | Constitution (77th Amendment) Act | 1995 | Inserted Article 16(4A) to allow SC/ST reservation in promotions. |
| 6 | Ashoka Kumar Thakur v. Union of India | 2008 | Upheld 27% OBC quota in higher education (Central Educational Institutions) under the 93rd Amendment. |
| 7 | Constitution (103rd Amendment) Act | 2019 | Provided 10% reservation to Economically Weaker Sections (EWS) among general category. |
| 8 | Jarnail Singh v. Lachhmi Narain Gupta | 2018 | Reaffirmed Nagaraj case but struck down the need to prove backwardness of SC/ST for promotions. |
| 9 | Maratha Reservation Case (Jaishri Laxmanrao Patil v. Maharashtra) | 2021 | Struck down 2018 Maharashtra law granting Maratha reservation; reaffirmed 50% ceiling. |
| 10 | State of Punjab v. Davinder Singh | 2020 & 2024 | Upheld sub-categorization of SCs within the 15% quota by states. |