Issues:

• Whether the State government had the power to sub-classify Scheduled Castes (SCs) for the purpose of reservation in public employment and education.

• Whether such sub-classification violated Article 14 (equality before law) and Article 16 (equality of opportunity in matters of public employment) of the Constitution of India.

• Whether the State government could create separate categories within the Scheduled Castes for the purpose of providing preferential treatment in matters of reservation.

Analysis:

• The Andhra Pradesh government had enacted a law providing for sub-classification of Scheduled Castes, giving preferential treatment to certain groups within the SCs. This was done to ensure that the benefits of reservation reached the most backward among the Scheduled Castes.

• The petitioners argued that this sub-classification violated the principle of equality enshrined in Articles 14 and 16 of the Constitution. They contended that once a group is notified as a Scheduled Caste, it forms a homogeneous class, and any further division within it is arbitrary and discriminatory.

• The State government argued that sub-classification was necessary to address the issue of "creamy layer" within the Scheduled Castes, ensuring that the benefits of reservation reached the truly disadvantaged.

• The Supreme Court analyzed the concept of Scheduled Castes and the purpose of reservation. It emphasized that the Constitution intended to uplift the entire Scheduled Caste community, which had historically suffered from social and economic discrimination.

• The court observed that the Presidential notification under Article 341 of the Constitution specifies the castes, races, or tribes that are to be deemed Scheduled Castes. These notified castes form a single class for the purposes of the constitution.

• The Supreme Court also analyzed previous judgments related to reservations and concluded that sub-classification of Scheduled Castes for the purpose of reservation was not permissible under the Constitution.

Judgment:

• The Supreme Court held that the State government did not have the power to sub-classify Scheduled Castes for the purpose of reservation.

• The Court ruled that Scheduled Castes, as notified under Article 341 of the Constitution, form a single class.

• The Court declared the Andhra Pradesh law providing for sub-classification of Scheduled Castes to be unconstitutional, as it violated Articles 14 and 16 of the Constitution.

Conclusion:

• E.V. Chinniah v. State of Andhra Pradesh is a significant judgment that clarified the scope of reservation policies concerning Scheduled Castes.

• It emphasized that the Presidential notification under Article 341 determines the constitution of Scheduled Castes, and any sub-classification by state governments is impermissible.

• This decision upheld the principle of equality and ensured that the benefits of reservation are distributed evenly among all members of the Scheduled Caste community.

• However, this issue has continued to evolve. More recently, there has been more legal and political movement towards discussing the idea of a "sub classification" again. Therefore, while this case was a very strong precedent, the questions it addressed are still being discussed.

Please note that the judgement has been over turned but is important for aspirants to track the trail of events (State of Punjab V. Davinder Singh 2024 SCC OnLine SC 1860)