Sub-Classification Within SC Reservations: Karnataka's Revised Internal Quota Formula
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.
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.
Key Details
- Karnataka's SC population is approximately 17% of the state population (basis for the original 17% quota before High Court cap).
- The 50% ceiling on reservations: Established in Indra Sawhney v. Union of India (1992) (Mandal Commission case) — total reservations cannot ordinarily exceed 50% of available posts.
- The Indra Sawhney judgment also held that reservations in promotions for SCs/STs are constitutionally impermissible (later overridden by constitutional amendments).
The revision from 17% to 15% is a direct consequence of the Indra Sawhney 50% ceiling; the 5.25:5.25:4.5 internal split operationalises sub-classification within the permissible SC quota.
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.
Karnataka's internal reservation formula is the direct legislative implementation of the Davinder Singh judgment. Without the 2024 ruling, such sub-classification would have been constitutionally impermissible.
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.
The Cabinet's approval of the 5.25:5.25:4.5 formula is a revised version of the Commission's recommendations, recalibrated for a 15% SC base (down from the Commission's 17% assumption).
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.
The High Court's directive that brought Karnataka's total reservation to 50% required the SC quota to be revised from 17% to 15%, triggering the recalculated 5.25:5.25:4.5 internal formula.
- 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