The Supreme Court of India recently delivered a significant judgment in the matter of Union of India & Others v/s Rohit Nandan concerning caste categorization and reservations, particularly addressing the entitlement of the Tanti caste to Scheduled Caste (SC) benefits. The apex court overturned a decision of the Patna High Court, holding that the inclusion of the Tanti caste in the SC list by the State Government of Bihar was unconstitutional and legally unsustainable.
Background:
The case originated with the appointment of the respondent as a Postal Assistant in 1997 under the Other Backward Caste (OBC) category, based on his Tanti caste certificate. However, in 2015, the Bihar government issued a gazette notification removing the Tanti caste from the OBC list and merging it with the Pan/Swasi caste in the SC category. Following this, the respondent obtained an SC certificate and sought recognition as an SC candidate for promotional benefits.
In 2016, the respondent applied for promotion as an SC candidate through the Limited Departmental Competitive Examination (LDCE). Although he successfully passed the examination, his appointment was withheld, and subsequent inquiries revealed that his categorization as an SC candidate was questionable. In 2019, the Department of Posts concluded, after consulting the Department of Social Justice and Empowerment, that the respondent was not entitled to SC benefits. The decision was challenged in the Central Administrative Tribunal (CAT) and later the Patna High Court, which ruled in favor of the respondent. The Union of India subsequently appealed to the Supreme Court.
Supreme Court’s Observations:
The Supreme Court based its decision on its earlier ruling in Dr. Bhim Rao Ambedkar Vichar Manch Bihar v. State of Bihar (2024), which declared the Bihar government’s 2015 notification unconstitutional. The Court reiterated that under Article 341 of the Constitution, only Parliament has the authority to amend the SC list. The state’s unilateral decision to include the Tanti caste in the SC category was deemed invalid.
The apex court noted that the High Court erred in its judgment by failing to address the constitutional limitations imposed by Article 341. It clarified that the state’s actions were not merely clarificatory but amounted to an unauthorized modification of the SC list, which could only be done through parliamentary legislation.
Equitable Considerations Rejected:
The respondent’s counsel argued for protection of the respondent’s position, citing precedents like K. Nirmala v. Canara Bank and Bhim Rao Ambedkar (supra), where courts allowed benefits to individuals despite irregularities in caste categorization. However, the Supreme Court differentiated those cases on the basis of their facts. The Court highlighted that in both precedents, the individuals had held their positions for significant durations before their caste categorization was challenged. In contrast, the respondent in this case had only briefly benefited from the disputed SC categorization, making equitable considerations inapplicable.
Final Verdict:
The Supreme Court restored the Central Administrative Tribunal’s decision, denying the respondent the benefits of SC categorization. The Court concluded that the respondent’s temporary promotion, based on an unlawful SC certificate, lacked any constitutional or equitable support. The appeal filed by the Union of India was allowed, and the High Court’s decision was set aside.
Implications of the Judgment:
This decision reinforces the principle that any inclusion or exclusion of castes in the Scheduled Caste or Scheduled Tribe lists must strictly adhere to constitutional provisions. It underscores the exclusive role of Parliament in determining such changes and invalidates any unilateral actions by state governments.
The judgment also clarifies the limits of equitable relief in cases involving illegal categorization and benefits derived therefrom. It sets a precedent for dealing with similar disputes and strengthens the constitutional safeguards around caste-based reservations.
