Facts
The respondent, Rohit Nandan, was appointed as a Postal Assistant in 1997 under the OBC category based on his ‘Tanti’ caste certificate. In 2015, the State Government issued a notification merging the ‘Tanti’ caste with the Scheduled Caste (SC) list. Following this, the respondent obtained an SC certificate and applied for a promotion as an SC candidate. However, after reconsideration, the government declared that he was not entitled to SC benefits, leading to the cancellation of his promotion. The respondent’s legal challenge succeeded in the High Court, prompting the Union of India to appeal to the Supreme Court.
Contentions of the Appellant
The Union of India argued that the State Government’s notification merging ‘Tanti’ with the SC list was illegal since only the Parliament has the authority to alter SC lists under Article 341 of the Constitution. They claimed that the respondent was wrongly granted SC status, making his promotion invalid.
Contentions of the Respondent
The respondent contended that he obtained a valid SC certificate from the competent authority and applied for promotion accordingly. He argued that his SC status was never officially cancelled and that the State Government’s notification entitled him to SC category benefits.
Issues:
- Whether the State Government was competent to merge the ‘Tanti’ caste with the Scheduled Caste list.
- Whether the respondent was entitled to benefits under the SC category based on the impugned notification.
- Whether the promotion granted based on the SC certificate should be sustained.
Observations/Findings by the Supreme Court:
The Court held that only Parliament can amend the SC list, making the State Government’s notification merging ‘Tanti’ with the SC list illegal. The respondent’s SC certificate, obtained under the invalid notification, was legally unsustainable. The Court emphasized that administrative benefits based on unlawful caste categorization could not be granted.
Principle of the Case:
Constitutional provisions under Article 341 must be strictly followed, ensuring that only Parliament can amend SC lists. Administrative actions violating this principle are invalid.
Final Order:
The appeal was allowed. The Supreme Court set aside the High Court’s order and restored the Central Administrative Tribunal’s decision dismissing the respondent’s claim for SC-based promotion.
Importance of the Judgment to Society:
The judgment underscores the constitutional principle that changes to the Scheduled Caste list must be made by Parliament, protecting the integrity of caste-based reservations. It ensures that administrative overreach in caste classification does not undermine social justice policies.
Case Citation:
Court Name: Supreme Court of India
Case Title: Union of India & Ors. vs. Rohit Nandan
Case No.: Civil Appeal No. 14394 of 2024 (Arising out of SLP (C) No. 18985 of 2023)
Date of Judgment: December 13, 2024
Judges: Justice Pamidighantam Sri Narasimha and Justice Manoj Misra
