ARTICLE 341 - POLITY

 

Why in News?

The Supreme Court Monday ruled states cannot make changes to the Scheduled Caste list published under Article 341 of the Constitution

 

Supreme Court Ruling and Authority

Supreme Court Ruling: States cannot alter the Scheduled Caste list under Article 341 of the Constitution.

Case Specifics: The Supreme Court quashed the 2015 Bihar government notification categorizing the Tanti-Tantwa community as Scheduled Caste.

 

State Government's Authority: The state government lacks competence or authority to modify Scheduled Castes lists under Article 341.

 

Court Findings

  • Error by Patna High Court: The Supreme Court identified a serious error by the Patna High Court in upholding the Bihar government's notification without proper reference to Article 341.
  • Nature of Notification: The notification was deemed "mala fide" and unpardonable "mischief."

 

Impact and Reallocation

  • Reversion to Original Category: The Tanti-Tantwa community is to be reverted to its original category of Extremely Backward Class.
  • Reallocation of Posts: Posts filled by Tanti-Tantwa community members under the SC quota should be returned to the Scheduled Castes category, and Tanti-Tantwa members should be accommodated in their original category.
  • Impact on Individuals: The court ruled that individual members of the Tanti-Tantwa community would not face termination, recovery for illegal appointments, or withdrawal of benefits.

 

Constitutional Provisions Governing Reservation in India

  • Part XVI deals with reservation of SC and ST in Central and State legislatures.
  • Article 15(4) and 16(4) of the Constitution enabled the State and Central Governments to reserve seats in government services for the members of the SC and ST.
  • The Constitution was amended by the Constitution (77th Amendment) Act, 1995 and a new clause (4A) was inserted in Article 16 to enable the government to provide reservation in promotion.
  • Later, clause (4A) was modified by the Constitution (85th Amendment) Act, 2001 to provide consequential seniority to SC and ST candidates promoted by giving reservation.
  • Constitutional 81st Amendment Act, 2000 inserted Article 16 (4 B) which enables the state to fill the unfilled vacancies of a year which are reserved for SCs/STs in the succeeding year, thereby nullifying the ceiling of fifty percent reservation on total number of vacancies of that year
  • Article 330 and 332 provides for specific representation through reservation of seats for SCs and STs in the Parliament and in the State Legislative Assemblies respectively.
  • Article 243D provides reservation of seats for SCs and STs in every Panchayat.
  • Article 233T provides reservation of seats for SCs and STs in every Municipality.
  • Article 335 of the constitution says that the claims of STs and STs shall be taken into consideration constituently with the maintenance of efficacy of the administration.
  • The 103rd Constitution Amendment Act, 2019, empowered both Centre and the states to provide 10% reservation to the EWS (Economically Weaker Section) category of society in government jobs and education institutions.

Historical and Legislative Context

  • 2011 Recommendation: In 2011, the Bihar government recommended including Tanti-Tantwa in the SC list as a synonym of “Pan, Sawasi, Panr,” which was not supported by the Registrar General of India.
  • 2015 Resolution: Despite the Registrar General's stance, the Bihar government passed the resolution on July 1, 2015.
  • Relevant Legislation: The Bihar Reservation of Vacancies in Posts and Services (for Scheduled Castes, Scheduled Tribes, and other Backward Classes) Act, 1991 (Act No.3 of 1992) had listed Tanti-Tantwa under Extremely Backward Classes at serial number 33.

 

Sources: https://indianexpress.com/article/india/top-court-quashes-bihar-decision-to-classify-tanti-tantwa-as-sc-9457846/