The Supreme Court set aside the High Court's decision, holding that the respondent, a Tanti caste member categorized as OBC, could not claim Scheduled Caste (SC) status under a Bihar Government notification of 2015. The Court reiterated that only Parliament can amend the SC/ST lists under Article 341 of the Constitution. The respondent’s promotional benefit as an SC candidate was declared invalid.

• Issue: The respondent’s claim to Scheduled Caste status following a state notification that merged "Tanti" caste (previously OBC) with SC.
• Held: State governments cannot amend SC/ST lists; such acts are unconstitutional. The respondent cannot claim SC benefits as the notification was illegal.
• Result: Appeal allowed; High Court judgment quashed.

Para 1-2:

• Appeal by Union of India challenging the High Court's decision allowing the respondent SC benefits based on a notification.

Background Facts

Para 3-6:

• The respondent, appointed as a Postal Assistant in 1997 under OBC, claimed SC status in 2015 after a Bihar government notification moved "Tanti" caste to SC.
• Respondent sought category change in service records and SC benefits for promotion, which was rejected.

Proceedings Before Tribunal and High Court

Para 7:

• Tribunal dismissed the respondent’s application.
• High Court upheld the respondent’s claim based on the notification and the unchallenged SC certificate.

Key Legal Development: Bhim Rao Ambedkar Case

Para 8-9:

• SC judgment in Dr. Bhim Rao Ambedkar Vichar Manch Bihar v. State of Bihar (2024 INSC 528) invalidated the Bihar notification for including "Tanti" caste in the SC list. The case held such amendments are the exclusive domain of Parliament under Article 341.

Equity Considerations and Distinctions

Para 10-13:

• Court noted equity protection granted in Bhim Rao Ambedkar and K. Nirmala v. Canara Bank (2024 INSC 634) applied to long-standing benefits but did not extend to the respondent’s recent promotion.

Lack of Equities and Final Decision

Para 14-16:

• The respondent's SC benefit, acquired for less than a year, lacked equitable grounds. Appeal allowed; respondent’s promotion and SC status invalidated.

Acts and Sections Discussed:

• Constitution of India:
  • Article 341(1) & 341(2): Defines Parliament's exclusive power to amend SC/ST lists.

Ratio Decidendi:

• A State Government cannot alter SC/ST lists; such changes require Parliamentary approval under Article 341 of the Constitution. Any benefits derived from unauthorized notifications are invalid.

Subjects:

Reservation, Constitution, Scheduled Castes, Administrative Law.

• • Article 341
  • Scheduled Caste Reservation
  • State Government Notification
  • Promotion in Government Service
  • OBC to SC Migration
  • Constitutional Validity