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Analytical Review Of The Supreme Court’s Ruling In State Of Punjab V. Davinder Singh: Re- Examining Sub-Categorization Within Scheduled Castes And Constitutional Boundaries




Kashaff Salim, St. Xavier's University, Kolkata


1. Contextual Background


The Supreme Court's verdict in State of Punjab v. Davinder Singh reignited the national conversation on affirmative action and the legal limits of social justice. At its core, the case centred on whether Indian states could further categorize Scheduled Castes (SCs) into sub- groups for more targeted reservation benefits—particularly in public employment and education.


This debate stems from empirical findings indicating that certain SC sub-castes have consistently secured greater representation and benefits, leaving others within the same category disadvantaged. In response, states like Punjab, Haryana, and Tamil Nadu introduced sub-quotas to rectify internal disparities.


Some key legislative efforts included:


  • Punjab Act, 2006: Section 4(5) of the Punjab Scheduled Castes and Backward Classes (Reservation in Services) Act allocated 50% of SC-reserved jobs to Balmikis and Mazhabi Sikhs, considered the most socio-economically suppressed among SCs.


  • Haryana Notification, 1994: SCs were split into Block A and Block B, each allotted half the reserved seats. While Block B included castes like Chamars, Block A consisted of less-represented SCs. A rotational mechanism was introduced to alternate priority.


    Tamil Nadu Arunthathiyars Act, 2009: This created a 3% sub-quota for Arunthathiyars, carved out from within the broader SC reservation to benefit the most disadvantaged.


    These policies were challenged for potentially violating constitutional provisions, particularly following the precedent in E.V. Chinnaiah v. State of Andhra Pradesh, leading to a referral of the issue to a larger bench in Davinder Singh for reconsideration.



Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878

Website: www.ijllr.com

Accessibility: Open Access

License: Creative Commons 4.0

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