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Sadhana Singh Dangi & Ors. v. Pinki Asati & Ors.

Civil Appeal · 2021 INSC 906Decided 16 Dec 2021
Civil Appeal No. 7781 of 2021
Justice Uday Umesh Lalit · Justice S. Ravindra Bhat · Justice Bela M. Trivedi

Background

This was a large batch of appeals arising from a Madhya Pradesh High Court judgment concerning the selection of Assistant Professors by the Madhya Pradesh Public Service Commission. The dispute centred on how "horizontal" reservation for women should interact with "vertical" reservation for categories like OBC, SC and ST: specifically, whether a woman from a reserved category who scored higher marks than general-category women candidates should be placed in the unreserved-women quota, or confined to her own reserved-category quota. The High Court had ruled that such meritorious reserved-category women could not claim unreserved seats, prompting both affected candidates and the State to appeal.

Decision Breakdown

The Supreme Court held that the controversy was squarely covered by its earlier decision in Saurav Yadav v. State of Uttar Pradesh, which had already settled that merit must take precedence: a reserved-category woman who is meritorious enough to qualify for an unreserved seat is entitled to it, and the unreserved category is not reserved only for those outside any social reservation category. The Court found the High Court's contrary approach incorrect, set aside its judgment, and restored the revised selection list. It also gave specific directions to protect meritorious candidates who had been delayed in appointment due to the litigation, ordering that their seniority and back pay be reckoned from the date their juniors were appointed.

Lesson Learnt

When reservation rules overlap, such as reservation for women alongside caste-based reservation, merit must still be given priority; a more meritorious candidate from a reserved category cannot be pushed out of a general/unreserved seat simply because they also belong to a reserved category.

Official source (sci.gov.in)View Judgment (PDF)

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