Telangana Becomes First State to Implement Sub-Categorisation of SCs

GS2 – Polity

Context :

Telangana has taken a pioneering step by becoming the first state in India to implement sub-categorisation among Scheduled Castes (SCs), also known as “reservation within reservation.” As per the recent government notification, SCs in the state will be divided into three distinct groups – Group I, II, and III – for the purpose of providing reservations in jobs and education.

What is SC Sub-Categorisation?

Meaning:
Sub-categorisation of SCs refers to segmenting the Scheduled Castes into smaller, internal groups to distribute reservation benefits more equitably.

Objective:
The primary goal is to address disparities by ensuring that underrepresented Dalit communities receive a fairer share of reservation benefits, rather than allowing dominant SC groups to continue receiving the majority of opportunities.

Judicial Background

• E.V. Chinnaiah v. State of Andhra Pradesh (2004):
  The Supreme Court struck down the Andhra Pradesh Act of 2000 that aimed to sub-categorise SCs. It ruled that all SCs constitute a single class as per Article 341, and any further division would infringe upon the Presidential list and violate Article 14 of the Constitution.
• Jarnail Singh v. Lachhmi Narain Gupta (2018):
  The Supreme Court upheld the application of the “creamy layer” principle to SCs and STs in promotions, opening the door to discussions on internal inequalities within these groups.
• State of Punjab v. Davinder Singh (2024):
  In a landmark 6:1 majority ruling by a seven-judge Constitution Bench, the Supreme Court validated the idea of sub-classification within SCs, stating that it aligns with Articles 14, 15, and 16 of the Constitution, provided the SC group is not uniform in socio-economic terms.

Why Sub-Categorisation is Needed

• Unequal Distribution of Benefits:
  Certain SC communities have consistently availed a larger portion of the reservation benefits, sidelining smaller and more disadvantaged castes.
• Intra-Caste Inequalities:
  The SC category includes diverse communities with varying socio-cultural and economic statuses. Sub-categorisation helps in targeting benefits to those who need them most.
• Rectifying Social Hierarchies:
  Sub-categorisation seeks to dismantle the internal hierarchies and dominant-subordinate structures that exist within the SC population.

Challenges and Concerns

• Administrative Burden:
  Dividing SCs into sub-groups requires intricate classification efforts, often complicated by regional diversity in caste names and identities.
• Data Limitations:
  The lack of recent and comprehensive caste-wise socio-economic data poses a challenge. The last full caste census was done in 1931, and the SECC 2011 data remains unpublished.
• Social and Political Sensitivities:
  More dominant SC groups may resist redistribution of quotas, potentially leading to tensions and fragmentation within Dalit communities.
• Implications for Other States:
  Telangana’s move may inspire similar demands in other states, leading to greater complexity in reservation politics and heightened regional disparities.

Recommended Approach

• Nationwide Caste Survey:
  Launch a transparent and scientific caste-based census to gather updated socio-economic data for informed policy-making.
• Regular Review Mechanism:
  Establish national and state commissions to periodically evaluate and adjust the sub-quotas based on evolving data and ground realities.
• Uniform National Guidelines:
  The central government could introduce legislation to standardise sub-categorisation across states. This would help avoid legal inconsistencies and maintain constitutional harmony.