Supreme Court Strikes Down Illegal SC Classification: Union of India vs. Rohit Nandan
The Supreme Court of India has ruled in favor of the Union of India in the case of Union of India & Ors. vs. Rohit Nandan, setting aside a Patna High Court judgment that had wrongly granted Scheduled Caste (SC) status to an individual from the ‘Tanti’ caste. The Court held that the State of Bihar acted beyond its constitutional authority by merging the ‘Tanti’ caste from the Other Backward Classes (OBC) list into the SC list through a 2015 notification. The ruling aligns with the Court’s earlier decision in Dr. Bhim Rao Ambedkar Vichar Manch Bihar vs. State of Bihar, affirming that only the Parliament can alter the SC and ST lists under Article 341 of the Constitution.
Background of the Case
The case revolved around the government employment of Rohit Nandan, who was initially appointed as a Postal Assistant in 1997 under the OBC category based on his Tanti caste certificate. The critical events in the case were:
- July 2, 2015: The Bihar government issued a gazette notification merging the ‘Tanti’ caste with the Pan/Swasi caste, which was already listed as an SC caste.
- September 29, 2015: Rohit Nandan obtained a fresh SC certificate from the District Magistrate, Patna.
- June 23, 2016: He requested the Chief Post Master General, Patna, to change his category from OBC to SC in his service records.
- October 7, 2016: He applied for a promotion to Postal Service Group ‘B’ under the SC category through a Limited Departmental Competitive Examination (LDCE).
- April 16, 2018: His exam results declared him successful, but his promotion was withheld.
- February 14, 2019: The Department of Posts, after consultation with the Department of Social Justice and Empowerment, rejected his SC claim, ruling that he did not belong to an SC community.
- April 1, 2022: The Central Administrative Tribunal (CAT) dismissed his case, upholding the government’s stand.
- January 19, 2023: The Patna High Court overturned the CAT decision, directing that his SC status be upheld.
Supreme Court’s Examination
The Supreme Court, led by Justices Pamidighantam Sri Narasimha and Manoj Misra, examined whether the Bihar government’s 2015 notification was legally valid.
1. Can a State Government Alter the SC List?
The Court referred to its decision in Dr. Bhim Rao Ambedkar Vichar Manch Bihar vs. State of Bihar, where it had ruled that only Parliament has the authority under Article 341 to alter the SC list. The Bihar government’s action in merging the Tanti caste with an SC caste was therefore unconstitutional.
“The State Government had no competence/authority/power to tinker with the lists of Scheduled Castes published under Article 341 of the Constitution.”
2. Validity of Rohit Nandan’s SC Certificate
The Court ruled that the SC certificate issued to Nandan was invalid because it was based on an illegal state notification.
“The respondent cannot claim the benefits of the Scheduled Caste Category since the merger of the Tanti caste with the Scheduled Caste list is bad in law.”
3. Impact of Earlier Court Rulings
The respondent relied on earlier cases where individuals retained benefits despite similar misclassifications. However, the Court distinguished this case by noting that Nandan’s claim was recent, unlike cases where individuals had served for decades under disputed caste certificates.
“The facts in this case are completely different… the benefit that accrued to him was for a short period of less than a year.”
4. Withdrawal of SC Status and Promotion
The Court ruled that since Nandan had wrongly claimed SC status, his promotion based on that claim must be reversed.
Final Judgment
The Supreme Court ruled:
- The High Court’s order was set aside.
- The CAT’s order dismissing Nandan’s claim was restored.
- Rohit Nandan’s promotion under the SC category was declared invalid.
- His employment records must reflect his original OBC status.
- The Bihar government’s 2015 notification regarding the Tanti caste was declared unconstitutional.
Implications of the Judgment
The ruling has far-reaching consequences for caste-based reservations in India:
1. Only Parliament Can Modify SC/ST Lists
This judgment reaffirms that state governments cannot unilaterally alter caste classifications.
2. State Governments Cannot Extend Benefits Illegally
The ruling prevents misuse of reservation policies by ensuring that only legally recognized SC communities receive benefits.
3. Employees Cannot Claim Benefits Under Invalid Certificates
Individuals who obtain benefits under questionable caste classifications risk losing them upon judicial scrutiny.
Conclusion
The Supreme Court’s decision in Union of India vs. Rohit Nandan reinforces the constitutional framework governing caste reservations. By striking down the Bihar government’s attempt to alter the SC list, the Court has ensured that reservation benefits are granted only within the legal framework established by Parliament.
Petitioner Name: Union of India & Ors..Respondent Name: Rohit Nandan.Judgment By: Justice Pamidighantam Sri Narasimha, Justice Manoj Misra.Place Of Incident: Patna, Bihar.Judgment Date: 13-12-2024.
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