Pattali Makkal Katchi vs A. Mayilerumperumal & Ors.
Background
Tamil Nadu has long reserved a total of 69% of seats in education and government jobs for Backward Classes, Most Backward Classes (MBCs), Denotified Communities (DNCs), Scheduled Castes and Scheduled Tribes. In February 2021, the State passed a new law (the 2021 Act) carving out a separate 10.5% reservation exclusively for the Vanniakula Kshatriya community (one of about 116 communities grouped together as MBCs/DNCs), based mainly on a recommendation letter from the chairman of the state Backward Classes Commission that relied on decades-old data and used population as the only yardstick. The Madras High Court struck down this law as unconstitutional, both for lack of legislative competence and for being an arbitrary, caste-based carve-out unsupported by proper data. Pattali Makkal Katchi (a Tamil Nadu political party that campaigned for this reservation) and others appealed to the Supreme Court.
Decision Breakdown
The Supreme Court agreed with the High Court's ultimate conclusion but for narrower reasons. It first held that Tamil Nadu did have the legislative power to pass the 2021 Act: the constitutional amendment restricting states from identifying new backward classes only affected who can add or remove entire communities from the backward-classes list (that power now sits with the President), not a state's power to sub-divide reservation percentages among communities already on its own list since 1994. However, the Court found the actual 10.5% carve-out itself unconstitutional: singling out just the Vanniakula Kshatriyas for special treatment among 116 similarly placed communities, based only on stale data and population figures with no genuine assessment of relative backwardness, violated the equal-treatment guarantees in Articles 14, 15 and 16. The Court also noted (without deciding it, since the law failed anyway) that the State likely should have consulted the National Commission for Backward Classes before making this major policy change. The 2021 Act was therefore struck down and the appeals dismissed, while the Court expressly left open a separate, still-pending challenge to the underlying 1994 reservation law.
Lesson Learnt
A state government has the power to fine-tune how existing reservation categories are internally divided, but any such internal carve-out must be backed by current, credible data and a genuine, reasoned basis for treating one group differently from others in the same category: population numbers or an outdated commission report alone will not survive constitutional scrutiny under the equality guarantees.