The Supreme Court of India, on October 4, 2024, dismissed a review petition challenging its earlier judgment that allowed for the sub-classification of Scheduled Castes (SCs) and Scheduled Tribes (STs). The review was sought against a 2023 judgment, where the Constitution Bench upheld the idea that further sub-categorization within these groups is constitutional, aimed at ensuring equitable distribution of reservations. The seven-judge bench led by Chief Justice of India (CJI) D.Y. Chandrachud stated that no valid grounds for a review had been presented by the petitioners.

The decision reaffirms the Supreme Court’s stance on the need to recognize disparities within SC/ST groups and address inequalities in access to reservation benefits. The ruling is significant for its potential to reshape how affirmative action policies are implemented across India, particularly within SC/ST communities.

### **Background: Understanding Sub-classification of SC/STs**

Sub-classification, or categorizing SCs and STs into smaller groups within their constitutional framework, has been a highly debated issue. The Constitution of India, under Articles 341 and 342, recognizes certain castes and tribes as SCs and STs, entitling them to benefits in education, employment, and political representation. However, within these groups, there are disparities—some castes have historically benefited more from reservations, while others remain marginalized.

The debate on sub-classification essentially revolves around ensuring equitable distribution of affirmative action. Certain sections of SC/ST communities have argued that the more dominant castes within these groups corner a disproportionate share of benefits. Sub-classification seeks to address this imbalance by ensuring that more disadvantaged sub-groups get their fair share.

### **The 2023 Judgment: A Historical Step Forward**

In 2023, a five-judge Constitution Bench of the Supreme Court ruled in favor of sub-classification, asserting that the Constitution allows for such internal categorizations to promote equality within SC/ST groups. The judgment was lauded by many for recognizing the need to ensure that benefits reach the most marginalized communities.

The Court observed that “equity and social justice are not merely about a rigid application of reservation percentages but about tailoring policies to the actual needs of the people.” The ruling highlighted that the true objective of reservation policies is not just to uplift entire communities but to ensure that the most deprived sections of society receive the benefits intended for them.

The judgment relied on previous rulings, including *Indra Sawhney v. Union of India* (1992), which recognized the need to categorize communities based on their level of socio-economic backwardness. The Court clarified that sub-classification does not violate the principles of equality but, rather, enhances them by ensuring that those most in need are uplifted.

### **The Review Petition: The Challenges Raised**

Despite the 2023 judgment’s progressive intent, several groups and individuals opposed sub-classification, arguing that it violates the basic structure of the reservation policy and undermines the uniformity of SC/ST benefits. The petitioners in the review plea contended that allowing such internal divisions within SC/ST groups would fragment their collective identity and weaken their political and social standing.

Additionally, the petitioners argued that sub-classification could lead to potential conflicts between different castes within the SC/ST communities, possibly intensifying intra-group rivalries. They also claimed that it was unconstitutional to “re-classify” a community after the President of India had already declared a list of SCs and STs under Articles 341 and 342 of the Constitution.

### **The Supreme Court’s Stance on the Review Petition**

In its ruling on the review petition, the seven-judge Constitution Bench led by CJI D.Y. Chandrachud firmly rejected the petitioners’ arguments. The Court stated that the petitioners had failed to present any new grounds that would warrant a review of the 2023 judgment. According to the Court, the challenge to sub-classification was based on an incorrect reading of the Constitution and a misunderstanding of the purpose of reservations.

The Bench reaffirmed that the Constitution allows for flexible affirmative action policies that can be tailored to address specific inequalities within SC/ST communities. The Court further emphasized that its 2023 judgment did not undermine the collective identity of SC/STs but instead sought to enhance social justice by ensuring that the most marginalized receive their due share.

In a particularly important observation, the Court noted that “the principle of equality enshrined in the Constitution does not demand uniformity but equity.” The Bench held that sub-classification was a legitimate means of achieving substantive equality, a principle that lies at the heart of the Indian Constitution’s social justice framework.

### **Implications of the Judgment: A Paradigm Shift in Reservation Policy**

The Supreme Court’s rejection of the review petition has wide-ranging implications for the future of India’s reservation policy. By upholding sub-classification within SC/ST groups, the Court has paved the way for more nuanced and targeted affirmative action measures that can address historical injustices faced by marginalized sub-groups within the SC/ST communities.

The judgment may prompt states and policymakers to revisit their reservation policies to ensure that the most deprived sections within SCs and STs are adequately represented. Several states, including Andhra Pradesh, Tamil Nadu, and Punjab, have already implemented sub-categorization within SCs for state government jobs and education, recognizing that certain castes within SCs have historically benefited more than others.

However, the decision also raises important questions about how sub-classification will be implemented in practice. Policymakers will need to ensure that these measures do not lead to increased friction within SC/ST communities. The task of accurately identifying the most deprived sub-groups and ensuring that they receive the benefits of affirmative action will be a complex one, requiring careful planning and execution.

Moreover, the judgment highlights the evolving nature of India’s affirmative action framework. The Court’s decision reflects a shift from a one-size-fits-all approach to reservations toward a more nuanced system that takes into account intra-group disparities. This shift, if implemented effectively, could lead to a more equitable distribution of benefits among India’s most marginalized communities.

### **Conclusion: A Landmark in India’s Social Justice Landscape**

The Supreme Court’s dismissal of the review petition against sub-classification of SC/STs marks a significant milestone in India’s ongoing journey toward social justice. By reaffirming the constitutionality of sub-categorization, the Court has upheld the principle that equality is not about uniformity but about ensuring that the most marginalized sections of society are not left behind.

While challenges remain in implementing sub-classification in a way that balances the interests of different sub-groups within SC/ST communities, the ruling represents a progressive step forward in ensuring that the benefits of reservations reach those who need them the most. As India continues to grapple with issues of inequality and social justice, this judgment will undoubtedly serve as a guiding precedent for future affirmative action policies.

In the words of CJI D.Y. Chandrachud, “The true test of affirmative action is not in how many people it uplifts, but in how effectively it reaches those at the very bottom of the social ladder.” The Court’s ruling on sub-classification is a powerful affirmation of this principle and a testament to its commitment to upholding the ideals of justice and equity enshrined in the Indian Constitution.

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