In the instant case, the seven judge Constitution Bench ruled by a majority of 6:1 that sub-classification within the Scheduled Castes (SCs) among reserved categories is permissible for granting separate quotes for more backwards within SC categories.
This decision addresses the Punjab Scheduled Castes and Backward Classes (Reservation in Services) Act 2006 (‘the Act’), which allocated 50% of SC reserved vacancies to Balmikis and Mazhabi Sikhs. This provision was challenged and declared unconstitutional by the Punjab and Haryana High Court based on the precedent in E.V. Chinnaiah v. State of A.P., (2005) 1 SCC 394, wherein, it was held that SCs cannot be further classified for the purpose of reservation because they constitute an internally homogenous class by virtue of their inclusion in the Presidential list and thus, as a class, groups within the SCs cannot be treated differently and any further classification and consequent preferential treatment were held to violate Article 14 of the Constitution of India, as it would amount to a constitutionally prescribed ‘micro-classification’.
The Supreme Court revisited the Chinnaiah (supra) case and clarified that sub-classification within SCs is permissible under Articles 14, 15 and 16 of the Constitution of India, provided that the class is not homogenous for the purpose of the law. It established that sub-classification must meet two criteria: it should have a rational principle of intelligible differentia, and this principle must be related to the purpose of the statute. Thus, the State in exercise of the power under Articles 15(4) and 16(4) can further classify the Scheduled Castes if (a) there is a rational principle for differentiation; and (b) the rational principle has a nexus with the purpose of sub-classification. The Court emphasized that Article 341 Constitution of India does not create a homogenous class, and that sub-classification does not violate it unless it gives exclusive benefits to certain SC groups over all reserved seats. This decision aligns with the broader principles established in Indra Sawhney v. Union of India and acknowledges the SCs as a socially heterogeneous class, allowing states to further classify them under Articles 15(4) and 16(4) if justified.