Case Note & Summary
The judgment arose from 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, which increased reservations for SCs from 15% to 17% and for STs from 3% to 7%. The lead petitioner, Mahendra Kumar Mitra, argued that this increase breached the 50% ceiling established by the Supreme Court, infringing upon Articles 14, 15, and 16 of the Constitution. The second petition, filed by graduates seeking appointments as Assistant Engineers, also contested the Act's implications on their eligibility. The court noted that the Act's provisions raised questions about the state's power to provide reservations and the implications of proportional equality. The petitioners contended that the reports justifying the increase lacked empirical data and failed to consider the representation of other castes. The state, represented by Prof. Ravivarma Kumar, argued that the 50% ceiling rule was no longer applicable due to the 103rd Amendment and that the Act was beneficial legislation. The court analyzed the arguments, referencing previous judgments and the necessity of consultation with national commissions. Ultimately, the court reserved its decision on the petitions, highlighting the need for careful consideration of the constitutional implications of the increased reservation (Paras 1-50).
Headnote
A) Constitutional Law - Reservation Policy - Increase in Reservation - Constitution of India, 1950, Articles 14, 15, 16 - The petitioners challenged the Karnataka Act increasing reservation for SCs and STs beyond 50%, arguing it violates the equal protection clause. The court examined the constitutional limits of reservation and the necessity of extraordinary circumstances for such increases. 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 its decision on the petitions, indicating the need for careful consideration of the constitutional implications of the increased reservation.
Law Points
- Reservation
- Constitutional validity
- Equal protection
- Articles 14
- 15
- 16
- Judicial review
- Proportional equality
Case Details
2026 LawText (KAR) (10) 57
WP No. 200448 of 2025, 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 percentages.
Remedy Sought
Petitioners sought to quash the Karnataka Act increasing reservation percentages.
Filing Reason
Petitioners argued the increase breached the 50% ceiling established by the Supreme Court.
Previous Decisions
Previous decisions established the 50% ceiling on reservations.
Issues
Whether the increase in reservation for SCs and STs beyond 50% is constitutionally permissible.
Whether the state has the power to provide for such an increase under the equality clauses.
Submissions/Arguments
Petitioners argued that the increase in reservation violates the equal protection clause and lacks empirical justification.
State contended that the 50% ceiling rule is no longer applicable due to the 103rd Amendment and that the Act is beneficial.
Ratio Decidendi
The court emphasized the importance of adhering to the 50% ceiling on reservations as established by precedent, while also considering the state's arguments regarding the necessity of increased reservations.
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.
Procedural History
The petitions were filed under Article 226 of the Constitution of India, challenging the constitutional validity of the Karnataka Act and related notifications. The court reserved its decision after hearing arguments from both sides.
Acts & Sections
- Karnataka Scheduled Castes and Scheduled Tribes (Reservation of Seats in Educational Institutions and Appointments or Posts in the Services under the State) Act, 2022: Section 1, Section 3, Section 4, Section 5
- Commissions of Inquiry Act, 1952: Section 3
