STATE OF PUNJAB VS DAVINDER SINGH (2024)

Case Name: State of Punjab vs Davinder Singh (2024)

Citations: 2024 INSC 562, AIR 2024 SC

Petitioners: State of Punjab, Director of Public Instructions, Gurbachan Singh and others

Respondents: Davinder Singh, Chamar Mahasabha, Lachman Singh and Others

Date of the Judgment:  1st August 2024

Court: Supreme Court of India

Bench: Seven-judge Constitution Bench- Justices D. Y Chandrachud, B. R. Gavai, Vikram Nath, B.M Trivedi, Manoj Misra, Pankaj Mithal and Satish Chandra Sharma

INTRODUCTION

The case of State of Punjab vs Davinder Singh (2024) a landmark judgment of the Hon’ble Supreme Court of India, this case deal with the complex issue of Castes-based reservation in India. In this case the focused on whether the Scheduled Castes (SCs) could be sub-classified to make sure that equitable distribution of reservation benefits those who are most disadvantaged groups. The case controversy dates back to the Punjab Scheduled Caste and Backward Classes (Reservation in Services) Act, 2006, which main aimed to provide special preference to the Balmikis and Mazhabi Sikhs within the Scheduled Caste category. The decision created legal challenged in the court that eventually leading to the Hon’ble Supreme Court judgment in 2024, which addressed the main question before the court was whether dividing the Scheduled Castes into such a sub-classification for the reservation purposes it is permitted under the Constitution of India.

In this case, the judgment is significant because it deals with the Articles 14, 15, and 341 of the Constitution, which is focus on equality, affirmative action, and social justice. It also stands out in the context of the earlier landmark cases, like E.V. Chinnaiah vs State of Andhra Pradesh (2004), and where it shows the ongoing development of legal thinking on the issue of caste-based reservations.[1]

FACTS OF THE CASE

In the year of 2006, the State of Punjab passed a law that reserved 50% of the Scheduled Caste quota seats specifically for Balmikis and Mazhabi Sikhs. The reason behind this provision passed was that the communities were officially being classified as Scheduled Castes (SCs), they have historically remained at the lowest level of socio-economic development and were not receiving a fair share of the benefits from the broader of Scheduled Castes category.

However, the Act was challenged and the case of E.V. Chinnaiah vs State of Andhra Pradesh (2004), where a Constitution Bench of Supreme Court had ruled that once a community is notified as a Scheduled Caste under Article 341 of the Constitution, it forms a “homogeneous class” that cannot be further sub-divided by states. Based on this judgement, the Punjab law was struck down by the Punjab and Haryana High Court.

The matter eventually reached the Hon’ble Supreme Court, where the main question was whether states have the power to create internal sub-classifications within Scheduled Castes to ensure that the most disadvantaged among them receive the intended benefits of social justice.

ISSUES RAISED

• Whether the State of Punjab has the legal power to divide the Scheduled Castes into sub-classification under the Article 341 of the Constitution?
• Whether dividing Scheduled Castes into sub-classification violates the right of equality guaranteed under the Articles 14 and 15 of the Constitution?
• Whether the Hon’ble Supreme Court requires reconsideration in the case of E.V. Chinnaiah (2004) judgment, which held that the Scheduled Castes cannot be split into such sub-classifications by states?
• Whether creating sub-classification within Scheduled Castes promotes to achieve true social justice or does it weaken the purpose of the reservation system?

CONTENTION

Petitioners’ Arguments:

• Unequal distribution within SC quota: The benefits of reservation had mostly gone to the relatively advanced Scheduled Castes sub-groups. As a result, leaving the most backward groups behind. Sub-classification seeks to address this imbalance by ensuring a fairer distribution of benefits.
• Support from Articles 14 and 15 of the Constitution: Under Article 15(4) of the Constitution allows the government to make special provisions for socially and educationally backward groups. This includes the power to ensuring the benefits are equally distributed even within the Schedule Castes (SCs).
• Precedent set by OBCs classification: Just as Other Backward Classes (OBCs) are already have been divided into categories like “backward” and “most backward” classes. A similar approach also should apply to the Schedule Castes (SCs) for more effective implementation of social justice.
• Social Justice Mandate: Equality under Article 14 of the constitution requires different treatment to uplift the weakest sections. A blanket quota for all SCs perpetuates inequality within the group.
• Dynamic interpretation: The constitutional provisions should be interpreted in light of evolving social realities. Strict adherence to the case of E.V. Chinnaiah judgment might stop real progress and prevent justice from reaching those who need it most.

Respondent’s Argument:

• Violation of Article 341: According to the Constitution, once a caste is recognized as a SC by Presidential notification under Article 341 of the Constitution, the states do not have the power to alter, sub-divide or modify that list. Allowing Sub-classification by states undermines constitutional authority.
• Need for Homogeneous treatment: All the Scheduled Cast (SCs) are historically treated as a single group because all faced untouchability and social exclusion. Breaking them into Separate categories risks creating within Scheduled Cast (SCs) will lead to both social and political fragmentation.
• Risk of political misuse: Allowing states the power to sub-classify could open the door to arbitrary and politically motivated reclassifications.
• Chinnaiah binding precedent: In the case of E.V. Chinnaiah a Constitution Bench of the Hon’ble Supreme Court clearly state that state cannot create sub-categories with the Schedule Castes list. Until this Decision is overturned by a larger bench.
• Possibility violation of Equality: Sub-classification may end up unfairly favouring certain Scheduled Cast (SCs) communities over others, even though many of them face the similar disadvantage. This could create fresh imbalances and go against the very idea of equality.

RATIONALE AND JUDGMENT

In the year of 2024, the Hon’ble Supreme Court delivered a significant and balanced judgment on this issue of Sub-classification within the Scheduled Castes (SCs). A seven-judge bench revisited the earlier decision in the case of E.V. Chinnaiah vs State of Andhra Pradesh (2004) and provided much-needed clarified the scope of Article 341 of the Constitution.

Overruling of Chinnaiah: The Court held that the E.V. Chinnaiah case was incorrectly decided. It clarified that Article 341 grants the exclusive authority to the President to identify which castes fall under the category of Scheduled Castes (SCs). However, once the list is notified, states retain the power to design policies for equitable distribution of benefit within the quota.

The Hon’ble Supreme Court overruled the case of E.V. Chinnaiah and confirmed that states have the constitutional authority to frame reservation policies under Articles 14, 15, and 16 of the Constitution. The Court held it clear that sub-classification within the Scheduled Castes (SCs) is constitutionally permissible, it provided the aims to promote substantive equality and does not remove any caste from the list notified under Article 341. The Court emphasized that formal equality that is simply treating all castes within the Scheduled Castes category same—is not sufficient to achieve the real social justice. Instead, policies must recognize the different levels of backwardness within the SC category to ensure that the most disadvantaged groups actually benefit. At the same time, to prevent misuse, the Court introduced important safeguards, stating that any sub-classification must be supported by reliable data and politically or arbitrary decisions would not be accepted.

This court decision represents a significant departure from the earlier view of Scheduled Castes as a single, uniform group which is laid down in the Chinnaiah case, and now allows states such as Punjab, Tamil Nadu, and Bihar the legal space to introduce sub-classification policies aimed at to ensuring more equitable distribution of reservation benefits within the Scheduled Caste community.

CONCLUSION

In 2024, the Hon’ble Supreme Court decision in the case of State of Punjab v. Davinder Singh was a major developing turning point in India’s reservation jurisprudence. By overruling the case of E.V. Chinnaiah and the court allowing states to address internal disparities within the Scheduled Castes (SCs) and ensure that the most disadvantage groups are not left out. It totally supported the idea of real meaningful equality and it also made it clear that any sub-division must be based on proper data and not political motives. Though this as a step to forward for social justice and it raises concerns about political misuse as well as potential divisions within the Schedule Castes community. Although, the judgement reflects the evolving approach to affirmative action, to making sure it’s about upliftment, not exclusion, and that it keeps up with today’s social realities.[2][3]

Reference(S):

[1] E.V. Chinnaiah v. State of Andhra Pradesh, (2004) 9 S.C.C. 524.

E V Chinnaiah Vs State of Andhra Pradesh and ors – Citation 667756 – Court Judgment | SooperKanoon

[2] State of Punjab v. Davinder Singh, (2024) 6 S.C.C. 401.

Supreme Court Observer – A living archive of the Supreme Court of India.,

The State Of Punjab vs Davinder Singh on 1 August, 2024, State of Punjab v. Davinder Singh

INDIA CONSTITUTION under article. 14, 15 & 341

Read – Constitution of India, Constitution of India | Legislative Department | India

[3]Validity of Sub-Classification Within Reserved Categories – Supreme Court Observer,

The State Of Punjab vs Davinder Singh on 1 August, 2024,

The State of Punjab Vs Davinder Singh – Citation 1231243 – Court Judgment | SooperKanoon