The Supreme Court ruled that the 'Tanti' caste, classified under OBC in Bihar, cannot avail Scheduled Caste benefits, citing the State’s lack of authority to amend Presidential notifications and the absence of equitable grounds.
In a significant ruling, the Supreme Court of India has refused to grant Scheduled Caste (SC) benefits to a Central Government employee from Bihar who belonged to the 'Tanti' caste. This decision came in the case Union of India v. Rohit Nandan, where the Court underscored that the Bihar Government lacked the power to reclassify the 'Tanti' caste from the Other Backward Classes (OBC) to the Scheduled Caste (SC) list.
The judgment was delivered by a bench comprising Justice PS Narasimha and Justice Manoj Misra, who determined that the respondent was not entitled to SC reservation for a Group B promotion in the postal department.
Background of the Case
- The employee was appointed as a Postal Assistant in 1997 under the OBC category.
- In 2015, the Bihar Government issued a notification shifting the 'Tanti' caste from the OBC list to the SC category, merging it with the ‘Pan/Swasi’ caste.
- Relying on this notification, the employee claimed SC reservation benefits for a Group B promotion through the Limited Departmental Competitive Examination (LDCE).
- The postal department rejected this claim, prompting the employee to seek relief through legal channels.
- The Patna High Court, in 2023, directed that the employee be granted SC status benefits after the Central Administrative Tribunal (CAT) dismissed his plea.
Supreme Court's Reasoning
- The Supreme Court highlighted its earlier decision in Dr. Bhim Rao Ambedkar Vichar Manch v. State of Bihar, delivered in July 2024, which held that State Governments lack the authority to amend Presidential notifications regarding caste classifications.
- In that case, the Court had invalidated the Bihar Government's notification that reclassified the 'Tanti' caste to the SC list but protected individuals who were already in service.
- The respondent relied on the K. Nirmala v. Canara Bank judgment, where employees retained their posts despite the State later declassifying their caste from SC.
Court’s Observations
- The bench clarified that the respondent's situation did not warrant the same protection as in previous cases. The Court stated:
“Even assuming that the respondent was given the benefit of his illegal categorization as a Scheduled Caste candidate, the benefit that accrued to him was for a short period of less than a year and that too during the pendency of this appeal.” - The Court noted that:
“There are no equities in favour of the respondent like that of the candidates in the case of Bhim Rao Ambedkar or K. Nirmala.” - Given the clear legal position and the limited duration of the benefit enjoyed by the respondent, the Court refused to extend SC benefits and overturned the High Court's decision.
Case : Union of India v. Rohit Nandan
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