Karnataka High Court Strikes Down SC/ST Quota Hike Beyond 50% Cap, Calls 2022
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The Karnataka High Court on Monday delivered a major constitutional ruling, invalidating key statutory provisions of a 2022 state enactment that enhanced reservation quotas for Scheduled Castes (SCs) and Scheduled Tribes (STs). A division bench presided over by Chief Justice Vibhu Bakhru and Justice K.S. Hemalekha ruled that pushing cumulative vertical quotas beyond the long-standing 50 percent constitutional ceiling directly contravenes fundamental rights guaranteed under the Constitution of India. The judgment nullifies the enhancement framework introduced under 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 had increased SC quotas from 15% to 17% and ST quotas from 3% to 7%.
Breaching the 50% Cap: Sections 3 and 4 Declared Ultra Vires
The division bench systematically struck down the statutory clauses that expanded quotas across state education and public employment:
Striking Down Educational Quotas: The bench declared Section 3 of the 2022 Act unconstitutional, observing that pushing overall reservations past the 50 percent threshold violates Articles 14 (Equality before Law) and 15 (Prohibition of Discrimination) of the Constitution.
Invalidating Government Job Enhancements: The court similarly quashed Section 4 of the statute, which mandated the augmented SC and ST quotas in state public service recruitment, declaring it a direct violation of Articles 14 and 16 (Equality of Opportunity in Public Employment).
The Indra Sawhney Precedent: Reaffirming binding legal jurisprudence, the bench underscored that the rigid 50 percent limit established by the Supreme Court of India in the landmark 1992 Indra Sawhney vs Union of India verdict—and consistently reaffirmed in subsequent constitutional bench rulings—remains an inviolable ceiling that cannot be breached without extraordinary and justified grounds.
The Legal Challenge: Engineering Aspirants and Federation Move Court
The constitutional test arose out of dual writ petitions questioning the legality of raising aggregate state reservations from 50 percent to 56 percent:
Petitions Against 56% Total Cap: The petitions contested the cumulative reservation surge that combined SCs, STs, and Other Backward Classes (OBCs) to push overall state allocations to 56 percent.
Representation by Dalit Federation: One of the lead petitions was brought before the court by Mahendra Kumar Mitra, state president of the Dr. Ambedkar Scheduled Castes Federation.
Challenge by Civic Engineering Aspirants: A joint petition was filed by civil engineering graduates Sagar H.R., Prajwal Kumar D., and Purushottam Gowda G.M., who had formally applied for Assistant Engineer (Civil) recruitment inside the Bruhat Bengaluru Mahanagara Palike (BBMP) and challenged the revised selection roster.
Origins of the Struck-Down Law: The Bommai Government and Commission Reports
The contentious legislation had been enacted during the previous administration following extensive judicial committee evaluations:
Legislative Trajectory: The statute was piloted and passed by the Karnataka Legislative Assembly under the Bharatiya Janata Party (BJP) government led by then Chief Minister Basavaraj Bommai.
Gubernatorial Assent and Notification: The enactment secured the Karnataka Governor's formal assent on January 11, 2023, and was subsequently notified in the Karnataka Gazette on January 12, 2023.
Grounding in Judicial Commission Recommendations: The statutory quota expansion was drafted relying on demographic representation studies submitted by the Justice (Retd.) H.N. Nagamohan Das Commission, along with supplementary evaluations prepared by a high-level committee headed by former High Court judge Justice Subhash B. Adi.
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