Telangana Becomes First Indian State to Implement SC Sub-Categorisation

 

1. SC Sub-categorisation means dividing the Scheduled Castes (SCs) into smaller groups based on their level of backwardness and ensuring reservation benefits are distributed more equitably among them particularly in education and public employment.
2. This is based on the observation that some SC sub-castes have disproportionately benefited from reservations, while others remain underrepresented.
3. Historically, some dominant SC sub-castes have cornered most of the benefits of reservation in education and jobs, leaving the most backward sub-castes underrepresented.
4. Sub-categorisation addresses this intra-group inequality.

What Happened in Telangana?

1. On April 14, 2025 (Ambedkar Jayanti), Telangana notified and implemented the Telangana Scheduled Castes (Rationalisation of Reservations) Act, 2025
2. Telangana now became 1st Indian state to formally implement sub-categorisation of Scheduled Castes in government jobs and education.
3. This follows the 2024 Supreme Court judgment in the case State of Punjab v. Davinder Singh.

Supreme Court Verdict Constitutional Support :

1.  E.V. Chinnaiah v. State of Andhra Pradesh (2004)
2. Issue: Could states divide SCs into sub-groups for reservations?
3. Verdict:
   1. The court in E.V. Chinnaiah held that once the caste is put on the Presidential List under Article 341(1).
   2. it becomes a homogenous class and there cannot be any further division of the said caste.
   3. Only Parliament can change the SC list.
4. Impact: Sub-categorisation by states was declared unconstitutional
5. But In August 2024,  in the case of State of Punjab v. Davinder Singh (2024), 7-judge Constitution Bench of the Supreme Court in State of Punjab v. Davinder Singh by a 6:1 majority overruled Chinnaiah.
6. It held that the state governments have power to sub-classify within the Scheduled Castes for providing reservations.
7. Key Observations:
   1. SCs/STs are not a homogenous class.
   2. Sub-classification helps provide justice to the most marginalised within reserved categories.
   3. States are allowed to sub-classify based on historical and empirical evidence.
   4. This paved the way for Telangana’s decision to withstand legal scrutiny.

Historical Attempts:

1. States like Punjab, Bihar, and Tamil Nadu have attempted sub-categorization, facing legal challenges that have reached the Supreme Court.

Legal Background

1. Act Passed: March 2025 (in Telangana Assembly)
2. Governor’s Assent: April 8, 2025
3. Gazette Notification: April 14, 2025 (on Dr. B.R. Ambedkar’s birth anniversary)

This act officially brought SC categorisation into effect in Telangana, after a detailed study and commission report.

 

How Was the Categorisation Done?

Telangana appointed a commission led by Justice Shameem Akther (Retd.), which:

1. Analyzed 59 Scheduled Castes in the state.
2. Recommended their division into three groups for rational allocation of the 15% SC reservation quota.

 The New SC Sub-Categories Are:

Group	Sub-Castes	Reservation Quota	Remarks
Group I	15 sub-castes (most backward)	1%	These sub-castes make up only 0.5% of the population
Group II	18 sub-castes (marginally benefited)	9%	Moderate representation in jobs & education
Group III	26 sub-castes (relatively better off)	5%	Already availing most of the benefits

Total SC reservation remains 15% – but is now split more fairly.

Who Will Benefit?

1. The most backward SC communities (Group I), who had minimal presence in public employment and higher education.
2. All underrepresented sub-castes now get a fairer share of reservation opportunities.

Key Implementation Details

1. Immediate effect: Sub-categorisation applies to all future recruitment and admissions.
2. Vacancies already notified are exempt from this new policy.
3. Government jobs and educational seats will now be allocated based on group-wise reservation.

Data and Analysis Used by Telangana

The government’s sub-categorisation was based on:

1. Empirical evidence from Justice Akther Commission.
2. Socio-economic and educational indicators of each SC sub-caste.
3. Political representation and access to government services.

Minister C. Damodar Rajanarsimha clarified

1. 33 of 59 sub-castes remained in the same group.
2. Only 26 sub-castes (3.43% of SC population) were shifted between groups.

Political Implications

1. The move is seen as part of the Congress government's strategy to consolidate support among:
   1. SCs and OBCs, who together make up ~70% of Telangana’s electorate.
2. Telangana also plans to increase OBC reservation to 42%, challenging:
   1. The 50% reservation cap set by the Indra Sawhney case (1992) and upheld in 2021 (Maratha quota judgment).

Constitutional Provisions Related to SC Sub-Categorisation

Article	Provision
Article 14	Guarantees equality before the law and equal protection of laws. It permits reasonable classification to achieve substantive equality.
Article 15(4) & 15(5)	Authorises the State to make special provisions for the advancement of socially and educationally backward classes, including SCs and STs, particularly in the field of education and admission to educational institutions.
Article 16(4)	Permits the State to provide reservation in public employment for any backward class of citizens that is not adequately represented in government services.
Article 341(1)	Empowers the President, in consultation with the Governor, to specify the castes, races, or tribes that shall be deemed as Scheduled Castes in a particular State or Union Territory.
Article 341(2)	Grants exclusive power to Parliament to include or exclude any caste from the SC list by law. States cannot make such changes unilaterally.

Note: Sub-categorisation does not alter who is an SC, but rather how reservation benefits are distributed within the SC list.

 

Arguments For and Against Sub-Categorisation

Aspect	✅ In Favour	❌ Against
Targeted Benefits	Helps most marginalised SC sub-castes access opportunities, as dominant groups have historically cornered the benefits.	Ignores that all SCs face caste-based stigma. Risks reinforcing caste divides further.
Internal Inequities	Recognises diverse levels of deprivation within SCs. Ensures inclusiveness within inclusivity.	Could fragment SC unity, reducing collective bargaining power.
Constitutional Validity	Backed by Article 14, 15(4), 16(4). Affirmed by Supreme Court (2024 ruling).	May be used for vote-bank politics. Risks moving away from larger anti-caste agenda.
Empirical Basis	States like Telangana used data, commissions, and studies to justify sub-groups.	Some argue that without a caste census, true data on intra-SC inequities is lacking or outdated.

 

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