M.R. Balaji v. State of Mysore

Case Title: M.R. BALAJI V. STATE OF MYSORE

Citation: AIR 1963 SC 649 | Court: Supreme Court of India

The State of Mysore reserved 68% seats in medical and engineering colleges. The Supreme Court struck it down. The Court said reservation should generally stay below 50%. “Class” is broader than caste. Article 15(4) allows special provisions, but they must be reasonable and balanced.

1. Is 68% reservation justified under Article 15(4)?
2. Can the State split “backward classes” into “backward” and “more backward” groups?

• Article 15(4) permits special provisions for socially and educationally backward classes and for SC/ST.
• Reservation should generally be less than 50% to keep balance with merit-based access.
• Executive orders can implement Article 15(4), but they must satisfy constitutional tests.
• “Class” ≠ “Caste”; multiple indicators matter: education, economy, occupation, region.

The Supreme Court invalidated the order. 68% was held to be excessive and outside the scope of Article 15(4). The Court laid down that reservation should generally be below 50%. It also rejected the split of backward classes into “backward” and “more backward” groups within Article 15(4).

Article 15(4) allows targeted help to backward classes and SC/ST, but the help must be reasonable and balanced. A very high quota like 68% upsets the balance between advancement of backward classes and open competition. “Class” cannot be read as “caste” alone.

• Introduced the 50% guideline for reservations.
• Clarified the meaning of “class” beyond “caste”.
• Balanced social justice with merit access in education.

Mnemonic: “Half Is Safe.”

1. Half: Keep reservation around half (below 50%).
2. Is: Indicators matter—education, economy, job, region.
3. Safe: Policies must be fair and balanced with merit.

Issue: Validity of 68% reservation and split into “more backward”.

Rule: Article 15(4) allows special provisions; reservation should generally be < 50%; “class” wider than “caste”.

Application: The order leaned heavily on caste; the quantum (68%) was too high; it risked excluding other deserving students.

Conclusion: Order invalid. Set aside by the Supreme Court.

Article 15(4)

Allows special provisions for SEBC and SC/ST in education.

Backward Class

Group identified by multiple factors: education, economy, occupation, area.

Quota (Reservation)

A set percentage of seats kept for identified groups.