Pichra Warg Kalyan Mahasabha Haryana v. The State of Haryana
Background
The Haryana government had issued notifications in 2016 and 2018 fixing an income-based "creamy layer" cut-off (excluding backward-class families earning above a threshold from reservation benefits) and further sub-dividing the remaining backward-class citizens into income brackets for priority in reservation. A welfare association and several students challenged these notifications, arguing that using income as the sole yardstick for "creamy layer" was contrary to earlier Supreme Court rulings. The Punjab and Haryana High Court had given mixed rulings, striking down the income sub-classification in one case while upholding the income-based creamy layer criteria in another, leading both sides to approach the Supreme Court.
Decision Breakdown
The Supreme Court held that identifying the "creamy layer" among backward classes cannot be based purely on economic/income criteria: social and other factors must also be considered, as laid down in the landmark Indra Sawhney case. Since Haryana's 2016 notification used income as the sole test, it was struck down as contrary to binding precedent and to the State's own 2016 Act, which required social, economic and other factors to be weighed together. The State was given three months to issue a fresh, legally compliant notification. Because the 2018 notification (on computing gross income) depended entirely on the now-quashed 2016 notification, the Court did not need to separately rule on it, and admissions/appointments already made under the old notifications were left undisturbed.
Lesson Learnt
Reservation policy that excludes backward-class citizens from benefits ("creamy layer") cannot rely on income alone: the government must also weigh social advancement, as the Constitution and Supreme Court precedent require a holistic test, not a purely financial cutoff.