📌 *HISTORY OF CASTE-BASED RESERVATION*
◾ *1882*
Reformers like Jyotirao Phule raised the need for reservations.
◾ *1932*
Poona Pact: Agreement between Dr. B.R. Ambedkar and Mahatma Gandhi for reserved seats for Dalits.
◾ *Post-Independence*
Constitution provided reservations for SCs and STs.
◾ *1990s*
OBCs included based on Mandal Commission recommendations.
📌 *CONSTITUTIONAL PROVISIONS FOR RESERVATION*
- *Article 15(4):* Reservation in education.
- *Article 16(4):* Reservation in government jobs.
- *Article 16(4A):* Promotion for SC/ST.
- *Articles 330 & 332:* Reservation in Parliament & State Assemblies.
- *Articles 243D & 243T:* Reservation in Panchayats & Municipalities.
- *103rd Amendment (2019):* 10% EWS reservation for economically weaker sections.
◾*1. State of Madras v. Champakam Dorairajan (1951)*
• First major case on reservation after Independence.
• Communal quota in education based on caste & religion struck down.
• Held: Reservation based purely on caste is unconstitutional.
• Led to 1st Constitutional Amendment, 1951 – Article 15(4) introduced.
◾*2. M.R. Balaji v. State of Mysore (1963)*
• 68% reservation in education for backward classes struck down.
• Held: Reservation should generally be below 50%.
• Caste alone cannot be sole criterion for backwardness.
• Invalidated classification into “Backward” & “More Backward” without proper basis.
◾*3. Indra Sawhney v. Union of India (1992)*
• Upheld 27% reservation for OBCs in govt. jobs (Mandal Case).
• Caste can be a valid indicator of social backwardness.
• Laid down key limits:
- Total reservation ≤ 50%
- Exclude creamy layer
- No reservation in promotion
◾*4. M. Nagaraj v. Union of India (2006)*
• Upheld Articles 16(4A) & 16(4B) (reservation in promotion).
• But held reservation in promotion is not automatic.
• State must prove:
- Backwardness of class
- Inadequate representation
- Maintaining administrative efficiency
• Reaffirmed 50% ceiling, creamy layer & catch-up rule.
◾ *5. Ashoka Kumar Thakur v. Union of India (2008)*
• Upheld OBC reservation in higher educational institutions.
• Creamy layer must be excluded.
• Reservation is a tool for social justice, not to destroy merit.
◾ *6. Suraj Bhan Meena v. State of Rajasthan (2011)*
• Reservation in promotion for SC/ST cannot be granted mechanically.
• State must collect quantifiable data to prove:
• Backwardness of community
• Inadequate representation
• Otherwise violates Art. 14 & 16.
◾ *7. Janhit Abhiyan v. Union of India (2022)*
• Upheld 103rd Constitutional Amendment (10% EWS reservation).
• Economic criteria held to be a valid basis for reservation.
• Excluding SC/ST/OBC from EWS does not violate Constitution.
◾ *8. State of Punjab v. Davinder Singh (2024)*
• 7-Judge Bench held: States can sub-classify SC/ST categories within the reserved quota.
• Overruled E.V. Chinnaiah.
• Sub-classifications ensure equitable distribution of benefits & helps the most marginalized.
◾ *9. Union of India v. G. Kiran (2026)*
• SC ruled: Candidates from SC, ST, OBC & EWS can be appointed to GENERAL CATEGORY POSTS if they achieve the cutoff marks set for general category.
• Reservation availability does not bar merit-based consideration for unreserved posts.
