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Issues: Whether the amended reservation regime under the Central Educational Institutions (Reservation in Admission) Act, 2006 applied to Manipur University so as to require reservation of 2% for Scheduled Castes, 31% for Scheduled Tribes and 17% for Other Backward Classes, instead of the general percentages under Section 3.
Analysis: The amended Act introduced the expression "specified north eastern region" and inserted provisos to Section 3 to address Central Educational Institutions in that region, particularly where the pre-existing reservation pattern for Scheduled Castes and Scheduled Tribes would otherwise be disturbed by the normal 27% OBC quota. The Court read the amendment in light of the Statement of Objects and Reasons and the parliamentary materials, holding that the provisos were designed to preserve the reservation pattern actually prevailing immediately before the commencement of the principal Act, and that the same factual base had to be used for working out both SC/ST and OBC reservation in the institutions covered by the proviso. On that basis, Manipur University could not revert to the general percentages in clauses (i) to (iii) of Section 3 after the amendment.
Conclusion: The amended proviso governed Manipur University, and the reservation pattern of 2% for SC, 31% for ST and 17% for OBC was upheld.