Sub-categorisation of Scheduled Castes: Need & Associated Challenges

• Context (IE): Telangana becomes 1^st state to implement Scheduled Castes (SCs) sub-categorisation, popularly called reservation within reservation. According to the notification, Scheduled Castes in the state will be divided into three categories – Group I, II and III.
• SC categorisation will be implemented in Telangana in employment and education.

What is Sub-Categorisation of Scheduled Castes (SCs)?

• Definition: SC Sub-Categorisation refers to the idea of dividing the Scheduled Castes (SCS) into sub-groups to ensure fairer distribution of reservation benefits among all SCS.
• Aim: Sub-categorising SCS aims to correct the imbalance/inequalities by reserving specific shares of benefits for smaller, less-represented Dalit communities.

Cases Related to Sub-Categorisation of SCs

• E.V. Chinnaiah v State of Andhra Pradesh (2004): The SC invalidated the Andhra Pradesh Scheduled Castes (Rationalisation of Reservations) Act 2000, which attempted to SC Sub-Categorisation.
  • Held that Scheduled Castes form a single class and cannot be subdivided. It stated that sub-classification would interfere with the Presidential list (Article 341) & violate Article 14 of the constitution.
    • Article 341 gives power to the President to specify castes, races or tribes that will be classified as ‘Scheduled Castes’ under the Constitution.
• Jarnail Singh v. Lachhmi Narain Gupta Case (2018): The Court held that the concept of the creamy layer would apply to SCs and STs for the purpose of promotions.
• State of Punjab vs Davinder Singh (2024): A 7-judge Constitution Bench upheld the validity of sub-classification within Scheduled Caste categories with a 6:1 majority.
  • The SC held that sub-classification within SCs is permissible under Articles 14, 15 and 16 of the Constitution of India, provided that the class is not homogenous for the purpose of the law.

Need for Sub-Categorisation of SCs

• Disproportionate Share in Opportunities: A few dominant SC communities have received a disproportionately large share of the benefits meant for all SCs.
• Address Inequalities Among Scheduled Caste Communities: Many smaller or more marginalized SC groups are left out, with minimal access to education, jobs, and political representation.
• Overcoming Hierarchy within Scheduled Castes: The SC category is not homogenous and comprises a wide range of communities with distinct cultural, social, and economic characteristics.

Possible Challenges

• Administrative Complexity: Categorising SC communities into sub-groups involves complex procedures. Variations in caste names and identities across regions can lead to confusion and disputes.
• Lack of Reliable and Updated Data: The absence of comprehensive, caste-wise data on socio-economic indicators makes it difficult to decide who should get how much.
  • The last caste census was conducted in 1931, and the Socio-Economic and Caste Census (SECC) 2011 data was never fully released.
• Political and Social Tensions: Dominant SC communities may oppose the division of reservation benefits. Sub-categorisation might create internal divisions and inter-caste conflicts within Dalit groups.
• Demands from Other States: Telangana’s move may encourage similar demands in other states, putting pressure on state and central governments. This could lead to the fragmentation of reservation politics and increased regional disparities.

Way Forward

• Conduct a Nationwide Caste-Based Survey: Initiate a scientific, updated, and comprehensive caste-based census or survey. Use the data as a foundation for evidence-based policy-making.
• Establish Review Mechanisms: Set up state-level and national-level commissions to periodically review sub-categorisation. These bodies should recommend adjustments in sub-quotas based on updated socio-economic conditions.
• Frame Uniform Guidelines at the National Level: The central government could consider enabling legislation to guide sub-categorisation efforts across states. This would ensure constitutional consistency, avoid legal disputes, and maintain a unified approach.