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In State of Punjab v. Davinder Singh (January 2024), the Supreme Court upheld the power of States to create sub-classifications within Scheduled Castes reservation. This judgment overruled which earlier precedent and on what basis?
- Overruled Indra Sawhney (1992) for lacking quantifiable data
- Overruled E.V. Chinnaiah (2004) for preventing States from addressing intra-group inequalities
- Overruled M. Nagaraj (2006) for imposing excessive conditions on reservation in promotions
- Overruled Jarnail Singh (2018) for excluding creamy layer in SC promotions
Answer: Overruled E.V. Chinnaiah (2004) for preventing States from addressing intra-group inequalities
Sub-classification jurisprudence evolution: (a) E.V. Chinnaiah (2004): Held States cannot sub-classify SCs as it would violate Article 14 by creating sub-categories within constitutionally recognized homogeneous group, (b) Davinder Singh (2024): 7-judge Constitution Bench (6:1) overruled Chinnaiah, holding: (i) States can create sub-classifications within SC/ST reservations to ensure equitable distribution among more/less backward communities, (ii) Classification must be based on quantifiable data showing backwardness, inadequacy of representation, (iii) Must maintain overall administrative efficiency, not violate Article 14 (rational classification, intelligible differentia), (c) Rationale: Addresses intra-group inequalities; ensures reservation benefits reach most marginalized within reserved categories, not just dominant sub-groups, (d) Applications: (i) State-level reservation policies: Punjab, Andhra Pradesh, Bihar can now sub-classify SCs based on empirical data, (ii) Quantifiable data requirement: States must conduct studies, collect data on social, educational, economic indicators, (iii) Judicial review: Courts will examine whether classification rational, based on intelligible differentia, (e) Illustrates adaptive affirmative action: Balancing group justice with intra-group equity; empirical basis ensuring reservations achieve transformative justice without undermining merit/administrative efficiency.