PATTALI MAKKAL KATCHI versus A. MAYILERUMPERUMAL & ORS.

PATTALI MAKKAL KATCHI versus A. MAYILERUMPERUMAL & ORS.

While the State had legislative competence to enact a law apportioning or sub-classifying reservation among communities already identified as MBCs and DNCs, the specific 2021 Act provision earmarking 10.5% for the Vanniakula Kshatriyas was struck down because the internal reservation was based solely on outdated population figures and there was no substantial, contemporaneous basis showing relative backwardness, inadequate representation or inability to compete vis-à-vis the other 115 communities; therefore the classification was unreasonable and violative of Articles 14, 15 and 16.

Parties
Appellant: Pattali Makkal Katchi; Respondents: A. Mayilerumperumal & Ors.
Jurisdiction
India
Judgment Date
31 March 2022
Procedural Posture
Civil Appeal / Appeal From High Court; Disposed by Supreme Court (final Disposal)
Outcome
Appeals dismissed in part; Supreme Court upheld High Court insofar as the Tamil Nadu Special Reservation Act, 2021 was declared ultra vires Articles 14, 15 and 16 for lacking a reasonable basis for the 10.5% internal reservation to Vanniakula Kshatriyas
Legal Topics
Backward Classes, Sub Classification of Backward Classes, Article 342 a, Article 31 B and Ninth Schedule, Article 338 B(9) Consultation Requirement, Articles 14, 15 and 16 Challenges
Constitutional Law Reservation Law Administrative Law Backward Classes Sub Classification of Backward Classes Article 342 a Article 31 B and Ninth Schedule Article 338 B(9) Consultation Requirement +1 more

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Legal principles 5 Authorities cited 21 Party arguments 2 Amounts and remedies 9
Sign in to unlock

Parties

Pattali Makkal Katchi

Appellant

A. Mayilerumperumal & Ors.

Respondents

Procedural Posture

Civil Appeal / Appeal From High Court; Disposed by Supreme Court (final Disposal)

Legal Issues

  1. 1 Whether the State Legislature had competence to enact the Tamil Nadu Special Reservation Act, 2021 after the 102nd and before the 105th Constitutional Amendment
  2. 2 Whether a statute placed in the Ninth Schedule (the 1994 Act) can be varied without amending that Act
  3. 3 Whether the State was required to consult the National Commission for Backward Classes under Article 338-B(9) before providing internal reservation

Ratio Decidendi

While the State had legislative competence to enact a law apportioning or sub-classifying reservation among communities already identified as MBCs and DNCs, the specific 2021 Act provision earmarking 10.5% for the Vanniakula Kshatriyas was struck down because the internal reservation was based solely on outdated population figures and there was no substantial, contemporaneous basis showing relative backwardness, inadequate representation or inability to compete vis-à-vis the other 115 communities; therefore the classification was unreasonable and violative of Articles 14, 15 and 16.

Court Disposition

Appeals dismissed in part; Supreme Court upheld High Court insofar as the Tamil Nadu Special Reservation Act, 2021 was declared ultra vires Articles 14, 15 and 16 for lacking a reasonable basis for the 10.5% internal reservation to Vanniakula Kshatriyas

Orders

  • Impugned Tamil Nadu Special Reservation of seats in Educational Institutions ... Act, 2021 declared violative of Articles 14, 15 and 16 to the extent it apportions 10.5% exclusively to Vanniakula Kshatriyas and is therefore ultra vires
  • Appeals disposed of (dismissed) as recorded in judgment