Internal reservation: Dalit Ministers hold meetings to arrive at a consensus ahead of Karnataka Cabinet meeting on March 5
Dalit Ministers in the Karnataka Cabinet held pre-meeting consultations to arrive at a broader consensus on internal reservation (sub-categorisation) for Scheduled Castes, ahead of a scheduled Cabinet discussion on March 5, 2026.
The issue has created significant political friction within the SC community in Karnataka, as different sub-groups compete for a larger share of the 17% SC reservation quantum.
The immediate political pressure arises from the SC Left community (historically more marginalised) demanding that sub-classification prevent dominant SC castes from cornering the bulk of reservation benefits.
Karnataka had already received the report of the Justice H.N. Nagamohan Das Commission — set up after the Karnataka Cabinet's October 2024 decision to implement sub-categorisation — which proposed five categories of SCs based on caste-wise backwardness.
The Cabinet meeting on March 5 was expected to decide on the framework for implementing the Supreme Court's August 2024 verdict authorising states to sub-classify SCs.
Supreme Court Judgment: State of Punjab v. Davinder Singh (August 1, 2024)
On August 1, 2024, a 7-judge Constitution Bench of the Supreme Court (headed by then CJI DY Chandrachud) delivered a landmark 6:1 ruling in State of Punjab v. Davinder Singh, upholding the constitutional validity of SC sub-categorisation. This overturned the earlier 5-judge bench ruling in E.V. Chinnaiah v. State of Andhra Pradesh (2004), which had held that SCs form a single, homogeneous class that cannot be further sub-divided.
The 2024 ruling held that: (a) states have the legislative competence to sub-classify within the SC list; (b) empirical data must justify the sub-classification; (c) the "creamy layer" principle — already applicable to OBCs — may be extended to SCs as a future policy option (though not mandatory yet); (d) the purpose is equitable distribution within the reserved category.
Key Details
- E.V. Chinnaiah (2004): held SCs are a "class within a class" that cannot be divided — states' sub-classification laws struck down
- Davinder Singh (2024): reversed this; states CAN sub-classify based on rational criteria and data
- Justice B.R. Gavai dissented on one aspect (creamy layer applicability to SCs)
- Creamy layer for OBCs: applied since Indra Sawhney v. Union of India (1992); income threshold currently Rs 8 lakh per year
- Article 16(4): enables reservation in public employment for "backward class of citizens" — judicial basis for carving sub-groups
Karnataka's Cabinet deliberation directly implements the 2024 Supreme Court ruling, making it among the first states to formally legislate sub-categorisation post-Davinder Singh.
Constitutional Architecture of SC Reservations
The constitutional basis for SC reservations rests on a cluster of Articles: - Article 341: President, in consultation with the Governor, notifies which castes constitute the Scheduled Castes for each state. Only Parliament can amend the SC list — states cannot add or remove castes. - Article 46: DPSP — State to promote educational and economic interests of SCs/STs and protect them from social injustice. - Article 15(4): Permits special provisions for socially and educationally backward classes and SCs/STs in education. - Article 16(4): Permits reservation in public employment for backward classes not adequately represented. - Article 335: Claims of SCs/STs to services shall be taken into consideration, consistent with efficiency of administration.
Sub-categorisation does not alter Article 341 (President's list remains unchanged); it only determines priority within the already-notified SCs for the purpose of reservations.
Key Details
- The 103rd Constitutional Amendment (2019) introduced 10% EWS reservation for economically weaker sections — applicable to unreserved categories only, not SCs/STs
- The 77th Amendment (1995) inserted Article 16(4A) — reservation in promotion for SCs/STs
- Karnataka's SC reservation quantum: 17% (of which sub-categorisation will allocate internal shares)
- Nagamohan Das Committee proposed 5 sub-categories within the 17%, ranked by socio-economic backwardness
Karnataka's Cabinet is determining the precise intra-17% allocation — the practical legislative step following the constitutional green light from the Supreme Court.
The "Creamy Layer" Debate Within SC Reservations
The creamy layer concept — excluding economically advanced members of a backward group from reservation benefits — has so far applied only to OBCs (not SCs/STs). This is because the Supreme Court in Indra Sawhney (1992) held that SCs/STs face a distinct form of social discrimination (untouchability) that cannot be addressed purely through economic markers.
However, the 2024 Davinder Singh ruling reopened this debate: Justice B.R. Gavai noted in his concurring opinion that the State should consider evolving a policy to exclude the "creamy layer" from SC reservations as well, arguing that those who have already availed benefits should give way to the truly marginalised within the community.
Key Details
- Current OBC creamy layer income ceiling: Rs 8 lakh per annum (2013, periodically revised)
- Creamy layer exclusion among OBCs: Central service + constitutional post holders' children are also excluded regardless of income
- Political sensitivity: extending creamy layer to SCs/STs would affect politically powerful SC dominant castes — hence the "wedge" within Karnataka's SC community
- National Commission for Scheduled Castes (Article 338) is a constitutional watchdog mandated to investigate complaints on SC welfare
The political tensions among Karnataka's Dalit Ministers reflect precisely this intra-community debate about who benefits from reservations — the dominant SC castes who have historically availed most benefits, or the most backward SC sub-groups.
- Supreme Court ruling: State of Punjab v. Davinder Singh, August 1, 2024 — 7-judge bench, 6:1 majority
- Prior ruling overturned: E.V. Chinnaiah v. State of Andhra Pradesh, 2004
- Karnataka SC reservation quantum: 17% of total seats/posts
- Karnataka Cabinet first approved sub-categorisation: October 2024
- Justice H.N. Nagamohan Das Commission: proposed 5 sub-categories within SC 17%
- Article 341: Presidential notification determines the SC list; only Parliament can amend it
- OBC creamy layer income ceiling: Rs 8 lakh per annum
- Article 16(4A): reservation in promotion for SCs/STs (77th Amendment, 1995)