Published On: November 17th 2025
Authored By: Priyanshu Singh
Amity University, Noida
1. Case Title
State of Punjab & Ors. v. Davinder Singh & Ors.
2. Citation
2024 INSC 562
3. Court
Supreme Court of India
4. Bench
D.Y. Chandrachud (CJI), B.R. Gavai, Vikram Nath, Pankaj Mithal, Manoj Misra, Satish Chandra Sharma, Bela M. Trivedi (dissent).
5. Date of Judgment
1 August 2024
6. Relevant Statutes/Key Provisions
Articles 15(4), 16(4), and 341 of the Constitution of India
7. Brief Facts
The case revolved around whether states have the power to sub-classify Scheduled Castes (SCs) and Scheduled Tribes (STs) for the purposes of reservations. Earlier, in E.V. Chinnaiah (2004), the Supreme Court had held that SCs formed a homogeneous group and no sub-classification was permitted. The Punjab government introduced a law to create sub-quotas within SC reservations, which was challenged.
8. Issues Involved
- Can SCs/STs be sub-classified for reservation purposes?
- Do state legislatures have the power to make such classifications despite Article 341?
9. Arguments
Petitioner (State of Punjab):
– Sub-classification is necessary to ensure the most backward among SCs/STs benefit.
– Articles 15(4) and 16(4) empower the state to make special provisions.
Respondent (Davinder Singh):
– Only Parliament has authority under Article 341 to modify the SC list.
– Sub-classification undermines the constitutional scheme and equality.
10. Judgment
The Court held (6-1 majority) that sub-classification of SCs and STs is constitutionally permissible. It overruled E.V. Chinnaiah (2004), stating that SCs and STs are not a homogenous group and states can create sub-classifications within them to ensure substantive equality. However, such classification must be backed by empirical data and should be proportionate.
11. Ratio Decidendi
States are empowered under Articles 15(4) and 16(4) to sub-classify SCs and STs for targeted affirmative action, provided it is supported by quantifiable data showing backwardness and inadequate representation.
12. Obiter Dicta
The Court observed that the creamy layer principle can be applied to SCs/STs to ensure the benefits reach the most disadvantaged groups.
13. Final Decision
The Court upheld the validity of sub-classification. The judgment allows states to design sub-quotas within SC/ST reservations, targeting the most disadvantaged groups. Justice Bela M. Trivedi dissented, holding that only Parliament has the authority under Article 341.
