Case Note & Summary
The dispute arose from the U.P. Public Service Commission's decision to cancel the selection of a candidate, Sanjay Kumar Singh, for a position reserved for Scheduled Tribes, based on the claim that his tribe, the Naga, was not recognized as a Scheduled Tribe in Uttar Pradesh. The candidate had applied as a Scheduled Tribe member and successfully passed the examinations, but the Commission later found that the Naga tribe was not listed in the Presidential order under Article 342. The candidate challenged the cancellation through a writ petition, which the High Court allowed, stating that there was no law preventing the extension of reservation benefits to Scheduled Tribe candidates from other States. The Supreme Court, however, overturned this decision, referencing previous judgments that clarified that Scheduled Tribe status is specific to each State and that migration does not grant rights to benefits in the new State. The court noted that the Naga tribe was not recognized in Uttar Pradesh and thus the candidate could not claim reservation benefits. The Supreme Court directed that the candidate be considered for appointment in the general category, should he have secured higher marks than those selected in that category. The appeals were allowed without costs, setting aside the High Court's judgment.
Headnote
A) Constitutional Law - Scheduled Tribe Reservation - Eligibility for Reservation - Constitution of India, 1950, Articles 341, 342 - The court held that a person belonging to a Scheduled Tribe in one State cannot claim reservation benefits in another State where that tribe is not recognized as a Scheduled Tribe. The ruling emphasized that the specification of Scheduled Tribes is state-specific and migration does not confer entitlement to benefits in the new State (Paras 18-30).
Issue of Consideration
Whether a candidate belonging to a Scheduled Tribe not recognized in Uttar Pradesh can claim reservation benefits in public service in that State.
Final Decision
The Supreme Court set aside the High Court's judgment, ruling that the respondent could not claim Scheduled Tribe benefits in Uttar Pradesh. The court directed that the respondent be considered for appointment in the general category, with the possibility of appointment if he secured higher marks than general category candidates.
Law Points
- Scheduled Tribe definition
- reservation benefits
- migration implications
- constitutional interpretation
- public service recruitment
