📌 Why is this in the News?
👉 Telangana became the first state in India to implement sub-categorisation of Scheduled Castes (SCs) under the Telangana Scheduled Castes (Rationalisation of Reservations) Act, 2025.
👉 This follows the 2024 Supreme Court verdict in State of Punjab v. Davinder Singh, which upheld the constitutionality of sub-classifying SCs and STs within existing reservations.
🧠 What is Sub-Categorisation?
It’s the division of an existing reserved category (like SCs) into smaller internal groups based on levels of backwardness, so that benefits reach those who need it the most.
🧾 Telangana’s Sub-Categorisation Act, 2025 – Key Points
👩🏫 Purpose: To ensure equitable distribution of the 15% SC reservation among all SC communities.
📋 Based on: A detailed report by the Shamim Akhtar Commission, which studied 8,600+ representations considering:
- Population
- Education & Literacy
- Employment
- Financial inclusion
- Political representation
| Group | No. of Sub-Castes | % of SC Population | Reservation (%) | Group Description |
|---|---|---|---|---|
| Group I | 15 | 3.29% | 1% | Most disadvantaged |
| Group II | 18 | 62.75% | 9% | Moderately benefitted |
| Group III | 26 | 33.96% | 5% | Relatively better off |
📌 Important Note: This classification remains within the existing 15% SC quota in the state. However, the government may revise the overall quota when new Census data is available.
🧑⚖️ What Does the Constitution Say?
| Article | Provision |
|---|---|
| Art. 14 | Allows reasonable classification for equality. |
| Art. 15(4), 15(5) | Enables special provisions for SCs/STs in education. |
| Art. 16(4) | Allows reservation in jobs for underrepresented backward classes. |
| Art. 341 | President defines SCs, Parliament can amend the list. |
⚖️ What Did the Supreme Court Say?
🟥 Past Ruling (2004 – Chinnaiah case):
- Sub-categorisation by states was illegal, as SCs were seen as a homogeneous group.
- Only Parliament can change the SC list.
🟩 New Ruling (2024 – Davinder Singh case):
- Overturned the old ruling.
- Said states can sub-classify SCs/STs if backed by data and not used for political gains.
- Aimed to improve targeted delivery of justice.
⚖️ Arguments – For vs Against Sub-Categorisation
| For | Against | |
|---|---|---|
| 🎯 Targeted Benefits | Helps the most marginalised within SCs who have not yet benefitted. | May ignore the common discrimination all SCs face. |
| ⚖️ Justice Within Justice | Prevents dominant sub-castes from monopolising reservation benefits. | Could divide unity of Dalit communities. |
| 📊 Data-Driven | Based on real socio-economic studies. | Risk of political misuse and vote-bank politics. |
| 📜 Constitutionally Valid | Permitted under Articles 14, 15, and 16 if well-reasoned. | May distract from larger goals like ending caste discrimination. |
🧩 What Can Students Learn?
This case is a perfect example of how law, data, policy, and social justice interact. It’s not just about reservations, but about how India continues to shape equity-based reforms using the Constitution.
📚 Practice Questions – For UPSC Learners
🔹 Prelims MCQ
Q1. Which of the following Articles of the Indian Constitution allows the State to provide reservations in public employment for backward classes?
a) Article 14
b) Article 15(4)
c) Article 16(4)
d) Article 341
✅ Answer: c) Article 16(4)
Q2. Consider the following statements regarding the Telangana Scheduled Castes (Rationalisation of Reservations) Act, 2025:
- It increases the SC reservation quota from 15% to 17.5% in Telangana.
- It sub-divides the existing SC quota into three groups based on backwardness.
- It was implemented after the Supreme Court’s Davinder Singh judgment of 2024.
Which of the above statements is/are correct?
a) 1 and 2 only
b) 2 and 3 only
c) 1 and 3 only
d) 1, 2 and 3
✅ Answer: b) 2 and 3 only
Q3. The Supreme Court in the Davinder Singh case (2024) allowed states to sub-categorise Scheduled Castes within the reservation quota. This decision overruled the earlier judgment in which case?
a) Indra Sawhney v. Union of India
b) M. Nagaraj v. Union of India
c) E.V. Chinnaiah v. State of Andhra Pradesh
d) Ashok Kumar Thakur v. Union of India
✅ Answer: c) E.V. Chinnaiah v. State of Andhra Pradesh
🔹 Mains Practice Questions
- “Sub-categorisation within Scheduled Castes is a step towards internal equity, not against the idea of unity.” – Discuss this statement in the context of the Telangana Act and recent Supreme Court ruling.
- What are the constitutional, social and political implications of allowing sub-categorisation within SCs and STs?
- Critically examine whether sub-categorisation of Scheduled Castes could help address the problem of unequal access to reservation benefits.
