Case Note & Summary
The case involved two writ petitions challenging the constitutional validity of the Karnataka Scheduled Castes and Scheduled Tribes (Reservation of Seats in Educational Institutions and of Appointments or Posts in the Services under the State) Act, 2022. The lead petitioner, Mahendra Kumar Mitra, argued that the Act's increase in reservation for SCs from 15% to 17% and STs from 3% to 7% breached the 50% ceiling established by previous Supreme Court rulings. The second petition, filed by civil engineering graduates, contested the legality of a notification issued by the Karnataka Public Service Commission that implemented the increased reservations. The court noted that the petitions raised significant questions regarding the state's power to provide for reservations under the equal protection clauses of the Constitution. The petitioners contended that the increase in reservation was unconstitutional and lacked empirical justification, while the state argued that the 103rd Amendment to the Constitution had altered the applicability of the 50% rule. The court analyzed various precedents and the legislative history surrounding the Act, ultimately reserving judgment on the matter. The decision would have implications for the future of reservation policies in Karnataka and potentially across India.
Headnote
A) Constitutional Law - Reservation Policy - Increase in Reservation - Constitution of India, Articles 14, 15, 16 - The petitioners challenged the Karnataka Act No. 01 of 2023, which increased reservation for SCs and STs beyond 50%, arguing it violates the equal protection clause. The court examined the constitutionality of the Act and the implications of the 50% ceiling rule, ultimately determining the necessity of extraordinary circumstances for such an increase. Held that the increase in reservation raises significant constitutional questions (Paras 1-50).
Issue of Consideration
Whether the increase in reservation for Scheduled Castes and Scheduled Tribes beyond 50% is constitutionally permissible.
Final Decision
The court reserved judgment on the petitions challenging the constitutional validity of the Karnataka Act No. 01 of 2023, which increased reservations for SCs and STs beyond 50%. The decision will address significant constitutional questions regarding the state's power to provide for reservations.
Law Points
- Reservation
- Constitutional validity
- Equal protection
- Articles 14
- 15
- 16
- Judicial review
Case Details
2026 LawText (KAR) (10) 55
WP No. 200448 of 2025 C/W WP No. 25515 of 2025
Vibhu Bakhru, K.S. Hemalekha
Mahendra Kumar Mitra, P.S. Rajagopal, Harsha P. Banad, Ravivarma Kumar, Vinayaka S. Pandit
Mahendra Kumar Mitra, Sagar H.R., Prajwal Kumar D., Purushotham Gowda G.M.
The Secretary to the Government of India, National Commission for Scheduled Castes, State of Karnataka
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Nature of Litigation
Challenge to the constitutional validity of a state law increasing reservation for SCs and STs.
Remedy Sought
Petitioners sought to quash the Karnataka Act No. 01 of 2023 and related notifications.
Filing Reason
Petitioners argued that the increase in reservation breached the 50% ceiling established by the Supreme Court.
Previous Decisions
Previous decisions established a 50% ceiling on reservations, which the petitioners claimed was violated.
Issues
Whether the increase in reservation for SCs and STs beyond 50% is constitutionally permissible.
Whether the Act and related notifications were enacted in compliance with constitutional provisions.
Submissions/Arguments
Petitioners argued that the increase in reservation violates the equal protection clause and lacks empirical justification.
State contended that the 103rd Amendment to the Constitution altered the applicability of the 50% rule.
Ratio Decidendi
The court examined the constitutionality of increasing reservations beyond 50%, emphasizing the need for extraordinary circumstances to justify such a departure from established legal principles.
Judgment Excerpts
The present petitions raise questions as to the width of the power of the State to provide for reservation within the scheme of the equal protection and equal opportunity clauses.
The principal question that arises for consideration is whether the increase in the reservation in favour of SCs and STs by the Act, which takes the aggregate reservation in the State beyond 50%, is constitutionally permissible.
The court examined the constitutionality of the Act and the implications of the 50% ceiling rule, ultimately determining the necessity of extraordinary circumstances for such an increase.
Procedural History
The petitions were filed under Article 226 of the Constitution of India, challenging the constitutional validity of the Karnataka Act No. 01 of 2023 and related notifications. The petitions were heard together and reserved for orders on 09.09.2026.
Acts & Sections
- Karnataka Scheduled Castes and Scheduled Tribes (Reservation of Seats in Educational Institutions and Appointments or Posts in Services under the State) Act, 2022: Section 1, Section 3, Section 4, Section 5, Section 8
- Commissions of Inquiry Act, 1952: Section 3
