Dr. Jaishri Laxmanrao Patil v. The Chief Minister & Ors. (Maratha Reservation Case)
Background
After years of agitation by the Maratha community in Maharashtra demanding reservation in government jobs and education, the State enacted the Maharashtra SEBC Act, 2018, granting the Maratha community 12% reservation in education and 13% in public employment, on top of the existing 50% reservation for other backward classes, SCs and STs. This pushed total reservation in the state well above 50%. The Bombay High Court had upheld the law but reduced the quantum. Several petitioners challenged this before the Supreme Court, which also had to decide whether its 1992 decision in Indra Sawhney (which capped reservations at 50% except in "exceptional circumstances") needed to be revisited, and how the newly inserted Article 342A (introduced by the 102nd Constitutional Amendment) affected states' power to identify socially and educationally backward classes.
Decision Breakdown
All five judges unanimously held that Indra Sawhney's 50% ceiling on reservations remained good law and did not need to be referred to a larger bench, and that Maharashtra had failed to demonstrate the "extraordinary" or "exceptional circumstances" needed to justify breaching that ceiling, so the Maratha reservation law was struck down as unconstitutional, with the Court also finding the underlying Backward Class Commission report did not actually establish that Marathas were socially and educationally backward or inadequately represented in public services. On a second, more divisive question, whether the 102nd Amendment stripped states of their power to identify backward classes for state purposes, the majority (Justices Bhat, Rao and Gupta) held that after this amendment, only the President (guided by the National Commission for Backward Classes) can notify the list of socially and educationally backward classes for all purposes of the Constitution, while Justices Bhushan and Nazeer dissented on this specific point, holding that states retained that power for state lists. The Court used its special powers under Article 142 to direct that existing state backward-class lists would continue to operate until the central list was published, to avoid a vacuum, and it protected students and employees who had already secured admissions or appointments before the Court's earlier interim order of September 2020.
Lesson Learnt
Reservations in India are constitutionally capped at 50% except in truly exceptional circumstances backed by solid data: a state cannot grant extra reservation to a politically influential community merely because of public pressure or incomplete data; and major constitutional amendments can significantly reallocate power between the Centre and the states in ways that take time, litigation and further legislative correction to fully work out.