Karnataka HC quashes dual caste classification for education and employment

In a significant judgment, the Karnataka High Court has held that a single community cannot be classified into separate categories for education and employment purposes.

Justice Suraj Govindaraj issued this ruling while instructing the state government to reclassify the ‘Balajiga/Banajiga’ community under Group B for employment purposes, in line with its classification for education, as per Article 16(4) of the Constitution.

The case was brought by V Sumitra, a resident of Kollegal taluk in Mysuru district, who had applied for a primary school teacher’s post under the OBC category.

At the time, she had completed her education identifying as a member of the ‘Balajiga/Banajiga’ community, which was classified under Group B.

She was appointed to the teaching position on Nov 17, 1993.

However, on Feb 19, 1996, a notice was issued stating that for employment purposes, her community would be considered under Group-D instead of Group-B.

This reclassification rendered her caste certificate invalid for claiming employment reservation.

Despite pursuing the matter through multiple legal forums—including the Appellate Authority in the Education Department and the Karnataka State Administrative Tribunal—her claim was repeatedly denied.

During this time, she discovered a government notification dated Oct 13, 1986, which categorized the ‘Balajiga/Banajiga’ community under Group-B for educational purposes (under Article 15(4)) and Group-D for employment (under Article 16(4)).

Challenging this dual classification, it was argued that since both Article 15(4) and 16(4) serve the same goal of affirmative action, a community cannot be treated differently under each.

Justice Govindaraj emphasized that constitutional guarantees of equality extend to reservations in both education and employment.

“The equal protection of laws would also, in my considered opinion, include reservation, since the protection by way of affirmative action is for the grant of reservation of a particular number of seats in education or a particular number of posts in employment.

Thus, the protection under Article 14 being subject to Article 15(4) and Article 16(4), there cannot be a discrimination of reservation inter se Article 15(4) and Article 16(4),” he said.

He further added, “It is declared that the classification of the ‘Balajiga/Banajiga community’ for the purpose of employment, being different from that for the purpose of education, is discriminatory and illegal and void ab initio and violative of Article 14 of the Constitution of India. The state having classified the ‘Balajiga/Banajiga community’ as Group B for education purposes, it is required for the state to classify the very same community as Group B for employment purposes and not under Group D.”

Accordingly, the court set aside the order rejecting Sumitra’s claim for Group-B reservation in employment and held that she is entitled to such classification.

Her appointment as a primary school teacher was ordered to continue with the benefit of Group B reservation.