In a landmark decision, a seven-judge bench of the Supreme Court, led by Chief Justice Dr. D.Y. Chandrachud, has affirmed the legitimacy of subclassifying Scheduled Castes (SCs) to enhance equity among the most disadvantaged within the group. The ruling, passed with a 6-1 majority, supports the idea that further classification within SCs is permissible when grounded in rational principles and aimed at achieving substantive equality.
Key Findings of the Judgment:
- Permissibility of Subclassification: The court validated that SCs can be subdivided if a rational basis is established, aligning with the goal of ensuring substantive equality. This means that subclassification is a legitimate tool for addressing internal disparities within SC communities.
- Homogeneity of Scheduled Castes: The judgment clarified that SCs are not a monolithic entity. Empirical evidence shows significant inequalities among different SC groups, debunking the notion of a uniform class as suggested by Article 341’s legal fiction.
- Scope of Subclassification: Any subclassification effort must be based on measurable data concerning backwardness and representation in state services. The court emphasized that such models must not exclude any SC groups from the benefits of reservation.
Chief Justice Chandrachud’s Opinion:
Chief Justice Chandrachud highlighted that the Constitution’s approach to equality has evolved to embrace a more substantive interpretation. He underscored that while merit and reservations have historically been at odds, the need to balance efficiency with substantive equality remains critical. The Chief Justice reiterated that the evolution of Article 16(4) and related amendments reflect ongoing efforts to address disparities and ensure fair opportunities for SCs.
Historical Context and Case Background:
The current ruling stems from the Supreme Court’s review of previous judgments, including the controversial E.V. Chinnaiah case, which had previously deemed subclassification of SCs unconstitutional. This case revisited and overturned that precedent, drawing on insights from Indra Sawhney and other key rulings that support the subclassification within backward classes.
The Supreme Court’s decision in this matter aims to refine and implement reservation policies effectively, ensuring that the most disadvantaged within the SC community receive the necessary support to achieve equality.
