Facts : R. Krishnaiah v. State of A.P
The case challenged the constitutional validity of two 2011 Office Memorandums creating a 4.5% sub-quota for religious minorities within the 27% OBC reservation in central government posts and educational institutions. The Andhra Pradesh government relied on general reports like the Ranganath Mishra Commission without specific empirical data to justify the sub-quota’s necessity.
Legal Issues
- Whether the sub-quota violated Articles 15(4) and 16(4) by lacking empirical evidence to prove unique backwardness of religious minorities compared to other OBC groups.
- Whether the Union government breached procedural mandates under the National Commission for Backward Classes (NCBC) Act by not consulting the NCBC before implementing the sub-quota.
- Interpretation of statutory obligations: Whether headings in legislation can override plain statutory language.
Judgment
The Andhra Pradesh High Court struck down the sub-quota, holding:
- The government failed to provide specific empirical data demonstrating the distinct backwardness of religious minorities within OBCs, as required under constitutional provisions.
- The NCBC’s consultation was mandatory under the NCBC Act, even though its advice was not binding2.
- Reliance on general reports (e.g., Ranganath Mishra Commission) was insufficient, reinforcing the principle that reservations must be based on contemporary, cadre-specific data.
- Statutory interpretation: Headings in legislation cannot control unambiguous text, emphasizing the primacy of clear statutory language over ancillary aids.
The decision underscored the judiciary’s strict scrutiny of reservation policies, mandating rigorous adherence to constitutional and procedural safeguards
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