Karnataka approves revised internal reservation for SCs within 15 pc quota

What Happened

• A special meeting of the Karnataka Cabinet cleared a revised internal reservation formula for Scheduled Castes within the overall 15% SC quota, paving the way for long-pending government recruitment processes.
• The revised formula allocates the 15% SC reservation as follows: 5.25% for SC (Left-Hand communities), 5.25% for SC (Right-Hand communities), and 4.5% for the remaining SC communities (including groups such as Bovi, Lambani, Koracha, Korama, and 59 nomadic communities).
• The earlier approved formula was based on a 17% quantum (in a 6:6:5 ratio), but the High Court's directive capping total reservations at 50% of posts required recalibration to a 15% SC base.
• The move implements the recommendations of the Justice H.N. Nagamohan Das Commission, which submitted a 1,766-page report in August 2025 after extensive survey and analysis.
• This follows the landmark Supreme Court judgment in State of Punjab v. Davinder Singh (2024), which overruled a 2004 precedent and held that sub-classification within SC and ST quotas is constitutionally permissible.

Static Topic Bridges

Constitutional Basis for Reservations — Articles 15 and 16

Reservations for Scheduled Castes and Scheduled Tribes are grounded in:

• Article 15(4): Empowers the State to make special provisions for the advancement of socially and educationally backward classes, or SCs and STs.
• Article 15(5): Inserted by the 93rd Constitutional Amendment (2005); extends reservation to private educational institutions.
• Article 16(4): Allows the State to make provisions for reservation in appointments/posts for any backward class not adequately represented in State services.
• Article 16(4A): Allows reservation in promotion for SCs and STs (inserted by 77th Amendment, 1995).
• Article 341: The President specifies the Scheduled Castes in relation to each State/UT by public notification (the Presidential List).
• Article 335: Claims of SCs and STs shall be taken into consideration in the making of appointments to services, consistent with the maintenance of efficiency of administration.

State of Punjab v. Davinder Singh (2024) — Overruling E.V. Chinnaiah

This is the most consequential Supreme Court judgment on reservation law in two decades.

E.V. Chinnaiah v. State of Andhra Pradesh (2004): - A five-judge Constitution Bench unanimously held that Scheduled Castes form a homogeneous class under the Presidential List (Article 341). - Any sub-classification within SCs would amount to modifying the Presidential List, which only Parliament can do under Article 341(2). - Therefore, state legislatures cannot sub-classify within the SC category — such sub-classification was held unconstitutional.

State of Punjab v. Davinder Singh (2024): - A seven-judge Constitution Bench, in a 6:1 majority, overruled E.V. Chinnaiah. - Chief Justice D.Y. Chandrachud led the majority holding: SCs are not a homogeneous class. Within the Presidential List, different communities face varying degrees of historical discrimination and backwardness. - States are constitutionally competent to sub-classify within the SC/ST categories based on empirical data and rational criteria — not on political or arbitrary grounds. - The majority held that sub-classification does not modify the Presidential List; it only distributes reservation benefits more equitably within an already-notified category. - Justice B.R. Gavai wrote separately to add that states must collect quantifiable data on backwardness before making sub-classification. - Sole dissent: Justice Bela M. Trivedi, who held that the E.V. Chinnaiah view should be upheld.

Justice H.N. Nagamohan Das Commission

The State Government of Karnataka constituted the Justice H.N. Nagamohan Das Commission to survey and recommend a formula for internal reservation within the SC category.

Key findings and recommendations: - The Commission submitted a 1,766-page report to the Chief Minister in August 2025. - It surveyed the 101 castes listed under Karnataka's SC category and found wide disparities in representation and socio-economic status among sub-groups. - The Commission recommended categorising the SC community into multiple sub-groups, with the most marginalised communities (characterised as "Dalit Left" and "Dalit Right" communities based on historical social hierarchies) receiving larger shares. - An additional 1% reservation was recommended for the most backward among SC communities (Adi Karnataka, Adi Dravida, Adi Andhra — AK, AD, AA communities). - 20% of posts available under Category C were recommended for 59 nomadic communities.

Indra Sawhney v. Union of India (1992) — The 50% Ceiling Rule

This nine-judge Constitution Bench judgment (decided November 16, 1992) is the foundational ruling on reservation policy in India.

Key holdings relevant here: - Total reservations in any cadre/grade cannot ordinarily exceed 50% of available posts. - Exceptions are possible only in "extraordinary situations" (e.g., remote/isolated regions with special circumstances). - "Creamy layer" must be excluded from OBC reservations (but this doctrine does not directly apply to SCs/STs). - Reservations in promotions for SCs/STs were held impermissible (subsequently overturned by constitutional amendments).

Key Facts & Data

• Karnataka's SC quota: 15% (revised from 17% to comply with 50% ceiling)
• Internal formula approved: 5.25% (SC Left) : 5.25% (SC Right) : 4.5% (Others, including nomadic groups)
• Earlier formula: 6% : 6% : 5% (based on 17% total SC quota)
• Justice H.N. Nagamohan Das Commission: Submitted 1,766-page report, August 2025
• State of Punjab v. Davinder Singh (2024): 6:1 Supreme Court ruling — sub-classification within SC/ST permissible
• Overruled: E.V. Chinnaiah v. State of Andhra Pradesh (2004) — which held SCs are a homogeneous class
• Constitutional basis: Articles 15(4), 16(4), 341 (Presidential List)
• Indra Sawhney v. Union of India (1992): 50% ceiling on total reservations
• Article 341: Presidential List specifies SCs — only Parliament can modify the list
• 77th Constitutional Amendment (1995): Inserted Article 16(4A) — reservations in promotion for SCs/STs
• States implementing sub-classification: Telangana, Haryana, Andhra Pradesh (preceding Karnataka)
• SC communities surveyed: 101 castes under Karnataka's Schedule