Court Upholds 50% Reservation Limit; State Authority in Identifying Backward Classes Clarified

The Court upheld the validity of the 50% reservation limit set in the previous judgment and ruled that there was no need to reconsider it. The Court found that the Maharashtra SEBC Act, 2018, granting reservations to the Maratha community, did not meet exceptional circumstances to exceed the reservation limit. Additionally, the Gaikwad Commission's report was deemed insufficient to justify surpassing the 50% reservation limit. The Constitution (102nd Amendment) Act, 2018, was clarified not to strip State Legislatures of their authority to identify socially and educationally backward classes, although the identification process was centralized. The Court affirmed that States still possess the power to legislate on backward classes without violating the federal structure of the Constitution.

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Issues Involved:
1. Whether the judgment in Indra Sawhney v. Union of India needs reconsideration.
2. Whether the Maharashtra SEBC Act, 2018, granting reservations to the Maratha community, is justified under exceptional circumstances.
3. Whether the Gaikwad Commission's report justifies the existence of extraordinary circumstances for exceeding the 50% reservation limit.
4. Whether the Constitution (102nd Amendment) Act, 2018 deprives State Legislatures of their power to identify socially and educationally backward classes (SEBCs).
5. Whether the States' power to legislate in relation to "any backward class" is abridged by Article 342A read with Article 366(26C).
6. Whether Article 342A abrogates States' power to legislate or classify SEBCs, affecting the federal structure of the Constitution.

Detailed Analysis:

1. Reconsideration of Indra Sawhney Judgment:
The Court concluded that the judgment in Indra Sawhney v. Union of India does not need reconsideration. The 50% reservation limit set in Indra Sawhney remains valid and binding. The Court emphasized that the principle of balance between equality and affirmative action must be maintained, and the 50% ceiling is essential to avoid a caste-based society.

2. Justification of Maharashtra SEBC Act, 2018:
The Court held that the Maharashtra SEBC Act, 2018, granting reservations to the Maratha community, is not justified under exceptional circumstances as contemplated by Indra Sawhney. The Court found no extraordinary circumstances to breach the 50% reservation limit.

3. Gaikwad Commission's Report:
The Court found that the Gaikwad Commission's report did not justify the existence of extraordinary circumstances for exceeding the 50% reservation limit. The data and facts collected by the Commission indicated that Marathas are not socially and educationally backward, and their representation in public services is adequate.

4. Impact of Constitution (102nd Amendment) Act, 2018:
The Court held that the Constitution (102nd Amendment) Act, 2018, does not deprive State Legislatures of their power to identify SEBCs. The amendment introduced Articles 338B and 342A, establishing a National Commission for Backward Classes (NCBC) and giving the President the power to specify SEBCs. However, the States can still make suggestions to the NCBC for inclusion or exclusion of communities.

5. States' Power to Legislate on Backward Classes:
The Court concluded that the States' power to legislate in relation to "any backward class" under Articles 15(4) and 16(4) is not abridged by Article 342A read with Article 366(26C). The States retain the power to provide reservations and other benefits to SEBCs, but the identification of SEBCs is now a central function.

6. Federal Structure and Article 342A:
The Court held that Article 342A does not abrogate the States' power to legislate or classify SEBCs, and it does not affect the federal structure of the Constitution. The amendment aligns the identification of SEBCs with the existing mechanism for SCs and STs, ensuring a uniform standard across the country.

Conclusion:
- The judgment in Indra Sawhney remains valid and does not need reconsideration.
- The Maharashtra SEBC Act, 2018, granting reservations to the Maratha community, is not justified under exceptional circumstances.
- The Gaikwad Commission's report does not justify breaching the 50% reservation limit.
- The Constitution (102nd Amendment) Act, 2018, does not deprive States of their power to identify SEBCs but centralizes the identification process.
- States retain the power to legislate on backward classes and provide reservations.
- Article 342A does not violate the federal structure of the Constitution.

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