What was decided in E.V. Chinnaiah?

The Supreme Court struck down AP’s law that split Scheduled Castes into sub-groups with separate quotas. It held the State had no power to tinker with the Presidential List under Article 341.

Why did Article 341 matter here?

Article 341 gives the President the power to notify which castes are Scheduled Castes. The State cannot re-group or sub-classify those entries by legislation or executive action.

Did the Court find a violation of Article 14?

Yes. Subclassification among SCs for separate quotas was held discriminatory and unreasonable, violating equality under Article 14.

What about legislative competence?

Using pith and substance, the Court held the Act effectively altered the Presidential List. This was beyond the State’s legislative power.

Does this case affect reservation policy?

Yes. It draws a clear line: States may provide reservations, but cannot sub-divide the Presidential List of SCs to redistribute quotas among sub-groups.

E.V. Chinnaiah v. State of Andhra Pradesh

E.V. Chinnaiah v. State of Andhra Pradesh (2005)

Easy English explainer on Article 341, subclassification of Scheduled Castes, Article 14, and State legislative power over reservations.

Supreme Court of India 2005 (2005) 1 SCC 394 Reservation • Equality ≈ 6 min read India

Quick Summary

Andhra Pradesh passed a law to divide the Scheduled Castes (SCs) into four groups and give each group its own quota. The Supreme Court said this is not allowed. Under Article 341, only the President can notify who is SC. States cannot split that list into sub-groups for fresh quota slices. The law also failed the equality test under Article 14 and was beyond the State’s legislative power.

Issues

Is the AP Act, 2000, violative of Article 341(2)?
Did the State have legislative competence to pass this law?
Does subclassification among SCs breach Article 14?

Rules

Article 341

SCs are identified by Presidential notification. States cannot alter, regroup, or split the list.

Articles 14, 15, 16

Subclassification within SCs for preferential treatment is discriminatory and unconstitutional.

Facts (Timeline)

State formed Justice Ramachandra Raju Commission to see who among SCs missed reservation benefits.

Report suggested scoping sub-groups based on relative backwardness.

AP split 57 SCs (from Presidential List) into 4 groups and fixed separate quotas for each.

Ordinance was issued; later replaced by the AP SCs (Rationalisation of Reservations) Act, 2000.

Writs challenged the measure for violating the Constitution and central SC Orders.

AP High Court upheld the Act. Appeals went to the Supreme Court.

Arguments

Appellants

SCs are one homogenous class by the Presidential List; State cannot sub-divide.
Article 341 bars any rearrangement by State law or executive action.
Group-wise quotas violate equality and reasonableness under Article 14.

Respondents

Reservation design is within State policy space.
Data showed some SC sections cornered benefits; re-balancing helps the most deprived.
Law distributes existing quota; it does not change the Presidential List.

Judgment

The Supreme Court struck down the Act as ultra vires. SCs stand as one notified class under Article 341. Any State law that rearranges, re-groups, or reclassifies castes in that list is unconstitutional. The measure failed legislative competence (by pith and substance it touched the Presidential List) and also offended Article 14.

Ratio

Only the President (and Parliament for changes) can determine the SC list under Article 341.
States cannot sub-classify SCs to split quotas among sub-groups.
Such subclassification violates equality and fails the test of reasonableness.

Why It Matters

The case draws a firm boundary: reservation policy can be shaped by States, but the identity and unity of the SC list cannot be touched by them. It preserves a central, uniform approach to who counts as SC across India.

Key Takeaways

Article 341 controls the SC list.

No splitting SCs into sub-quotas by State law.

Subclassification among SCs breaches Article 14.

Pith and substance: Act lacked competence.

Mnemonic + 3-Step Hook

Mnemonic: “PIL-341” — Presidential List • Inviolate • Legislative limit • 341 controls.

Check List: Is it the Presidential SC list?
Check Power: Does the State try to re-group it?
Check Equality: Does it create unfair sub-quotas?

IRAC Outline

Issue

Can a State sub-classify SCs and allocate separate quotas among them?

Rule

Article 341 (Presidential List), and equality clauses—Articles 14, 15, 16—bar such subclassification.

Application

By pith and substance, the Act altered how the Presidential List worked—beyond State competence and unequal in effect.

Conclusion

Act declared ultra vires; subclassification of SCs struck down.

Glossary

Presidential List: The official list of Scheduled Castes notified by the President under Article 341.
Subclassification: Breaking one group into smaller groups for separate treatment or quotas.
Pith and Substance: A test to find a law’s true nature to see if the right legislature made it.