Dr. K. Krishnamurthy v. Union of India (2010)

The Supreme Court upheld the idea of reserving seats (and chairperson posts) for backward classes in local bodies. But it set a key condition: reservations must rest on fresh, local data and be reviewed often. Over-reservation is not allowed. Equality means giving real chances to those historically left behind.

• Court: Supreme Court of India
• Citation: (2010) 7 SCC 202
• Area: Constitutional Law, Local Governance

Is reservation for backward classes, including chairperson posts in panchayats and municipalities, valid? If valid, how should the State design and limit such reservations?

• Articles 243D & 243T: Allow reservation for backward classes in local self-government (seats and chairpersons).
• Articles 14, 15(4), 16(4): Permit affirmative action to achieve real equality.
• Separate Identification: Backward classes for local bodies need not match lists for education or public jobs.
• Empirical Basis & Review: Use updated local data; revise periodically to avoid excessive reservation.

The Court upheld reservations for backward classes in local bodies and chairperson posts. It stressed that identification must rely on updated empirical data and be reviewed often. Overbroad or excessive quotas are unconstitutional. Women’s reservation was noted to improve social welfare outcomes.

Affirmative action in local governance is compatible with equality, if crafted with evidence and limits. Backward classes for local bodies can be identified independently, but the extent of reservation must match local data and be kept within constitutional bounds.

• Guides States on designing lawful OBC reservations in local bodies.
• Insists on data, reviews, and limits to prevent excess.
• Supports women’s leadership and inclusive grassroots democracy.

• Reservations in local bodies are valid but must be evidence-based.
• Backward class lists for local bodies can differ from those for education/jobs.
• Periodic review prevents over-reservation and protects equality.

Mnemonic: DATA-FIT-REVIEW

• DATA = Identify groups using fresh empirical data.
• FIT = Match quota size to local population & need.
• REVIEW = Revisit periodically; avoid excess.

3-Step Hook:

1. Identify: Who qualifies locally?
2. Calibrate: How much reservation is justified?
3. Audit: When is the next review due?

Issue: Are reservations for backward classes in local bodies and chairperson posts constitutionally valid?

Rule: Articles 243D & 243T allow such reservations; equality clauses permit affirmative action with safeguards.

Application: The Court accepted reservations but required data-driven identification, local calibration, and periodic review to prevent excess.

Conclusion: Valid in principle; must be evidence-based and limited to remain constitutional.

Local Bodies

Panchayats and municipalities that govern at village, town, or city level.

Backward Classes

Social groups identified as disadvantaged; for local bodies, they can be listed using local data.

Empirical Data

Reliable, updated information (surveys, numbers) used to design policy.

• K. C. Vasanth Kumar (1985): Criteria for identifying backward classes.
• Indra Sawhney (1992): Broad framework on reservations and limits.
• Subsequent Local Body Reservation rulings: Emphasised data-backed calibration and review.