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In Davinder Singh case (2024), the Supreme Court held that States can create sub-classifications within SC reservation to ensure equitable distribution of benefits, provided the classification is based on ______ data showing backwardness and inadequacy of representation.
- anecdotal
- quantifiable
- political
- historical
Answer: quantifiable
Sub-classification jurisprudence: (a) Davinder Singh (2024): 7-judge Constitution Bench (6:1) overruled E.V. Chinnaiah (2004), holding States can create sub-classifications within SC/ST reservations to ensure equitable distribution among more/less backward communities, (b) Conditions for valid sub-classification: (i) Quantifiable data: Empirical evidence showing intra-group inequalities in social, educational, economic indicators, (ii) Inadequacy of representation: Proof that certain sub-groups within SCs/STs remain underrepresented despite overall reservation, (iii) Administrative efficiency: Sub-classification must not undermine merit, efficiency in public services, (iv) Article 14 compliance: Classification must be rational, based on intelligible differentia, not arbitrary, (c) Applications: (i) State-level policies: Punjab, Andhra Pradesh, Bihar can now sub-classify SCs based on empirical data, (ii) Data collection: States must conduct studies, collect disaggregated data on SC sub-groups, (iii) Judicial review: Courts will examine whether classification rational, based on intelligible differentia, (d) Broader principle: Substantive equality requires addressing layered inequalities; calibrated affirmative action ensures benefits reach most marginalized within reserved categories, (e) Illustrates adaptive equality jurisprudence: Article 14 interpreted to permit sub-classification for intra-group equity; empirical basis ensures reservations achieve transformative justice without undermining merit.