Maratha Reservation Case: Jaishri Laxmanrao Patil v UOI
The Maratha reservation case (Jaishri Laxmanrao Patil v UOI) held that states lost power to identify SEBCs after the 102nd Amendment Act, 2018.
At a glance
Jaishri Laxmanrao Patil v Union of India — the Supreme Court case on whether states could identify Marathas as an SEBC after the 102nd Amendment Act, 2018.
Jaishri Laxmanrao Patil v Union of India — Constitution Bench, 3:2 majority, held states lack power to independently identify SEBCs.
Article 342A empowers the President to notify, by public notification, the SEBCs for a state or Union territory.
Tied the fate of Maharashtra's Maratha reservation law to the interpretation of the newly inserted Articles 338B and 342A.
Maratha reservation case refers to Jaishri Laxmanrao Patil v Union of India, the Supreme Court ruling that examined whether a state could grant reservation to the Maratha community as a Socially and Educationally Backward Class (SEBC) after the Constitution (102nd Amendment) Act, 2018 came into force. A Constitution Bench decided the matter by a 3:2 majority, holding that states no longer had an independent power to identify SEBCs once Articles 338B and 342A had been inserted into the Constitution.
Background of the Case
After the Constitution (102nd Amendment) Act, 2018 was enacted, the Maharashtra government passed a law recognising the Maratha community as an SEBC and extending reservation benefits to it on that basis. The law was challenged before the Supreme Court. The central constitutional question was whether a state retained the authority to identify its own SEBCs for reservation purposes once the 102nd Amendment had reorganised how backward classes are identified at the national level.
What the 102nd Amendment Changed
The Constitution (102nd Amendment) Act, 2018 inserted three new provisions into the Constitution, all concerned with the Central List of Socially and Educationally Backward Classes — commonly known as the Other Backward Classes (OBCs):
| Provision | What it introduced |
|---|---|
| Article 338B | Constitutional status to the National Commission for Backward Classes (NCBC) |
| Article 342A | Mechanism for notifying the Central List of SEBCs |
| Article 366(26C) | Definition of "socially and educationally backward classes" |
Under Article 342A, the President may, with respect to any state or Union territory, specify by public notification the socially and educationally backward classes which shall, for the purposes of the Constitution, be deemed to be SEBCs in relation to that state or Union territory. Article 366(26C) defines "socially and educationally backward classes" as such backward classes as are deemed to be so under Article 342A for the purposes of the Central Government or the state or Union territory, as the case may be. The stated legislative intent behind the 102nd Amendment was to deal with this Central List of SEBCs.
The Supreme Court's Verdict
In Jaishri Laxmanrao Patil v Union of India, a Constitution Bench of the Supreme Court, by a 3:2 majority, held that after the enactment of the Constitution (102nd Amendment) Act, 2018, the states lack the power to identify Socially and Educationally Backward Classes on their own. The majority reasoned that with the insertion of Articles 338B and 342A, the process of including, excluding, or modifying entries in the SEBC list no longer lies solely within the domain of individual state legislatures. On this reasoning, the Maharashtra law recognising Marathas as an SEBC fell outside the state's competence.
Aftermath
Article 342A was subsequently amended by the Constitution (105th Amendment) Act, 2021, in the period after this judgment. The amendment addressed the very question of SEBC-identification power that the case had turned on.
Significance
The Jaishri Laxmanrao Patil ruling is significant because it directly tied the fate of a state's reservation policy to the interpretation of a recently inserted constitutional provision, Article 342A, rather than to the reservation policy itself. It illustrates how a change to the constitutional scheme for identifying backward classes — introduced through the 102nd Amendment for a stated purpose — can have consequences for state-level reservation laws built on an earlier understanding of state power. The case remains a key reference point for understanding the relationship between Articles 338B, 342A and 366(26C), and for tracing why Parliament subsequently revisited Article 342A.
UPSC Relevance
Prelims
- Article 342A deals with the Central List of Socially and Educationally Backward Classes (SEBCs); inserted by the Constitution (102nd Amendment) Act, 2018.
- Article 338B gives constitutional status to the National Commission for Backward Classes.
- Article 366(26C) defines "socially and educationally backward classes" with reference to Article 342A.
- Jaishri Laxmanrao Patil v Union of India was decided by a Constitution Bench with a 3:2 majority.
Mains
- Discuss the constitutional questions raised by the Jaishri Laxmanrao Patil v Union of India case regarding the identification of Socially and Educationally Backward Classes.
- Examine how the insertion of Articles 338B and 342A by the Constitution (102nd Amendment) Act, 2018 affected the states' power to frame reservation policy for backward classes.
FAQ
Q1. What is the Maratha reservation case? It is the Supreme Court case Jaishri Laxmanrao Patil v Union of India, which examined whether Maharashtra could grant reservation to the Maratha community as an SEBC after the Constitution (102nd Amendment) Act, 2018.
Q2. What did the Supreme Court decide? A Constitution Bench, by a 3:2 majority, held that after the 102nd Amendment Act, 2018, states lack the independent power to identify Socially and Educationally Backward Classes.
Q3. Which constitutional articles were central to the case? Articles 338B, 342A and 366(26C), all inserted or shaped by the Constitution (102nd Amendment) Act, 2018.
Q4. What is Article 342A about? It empowers the President to notify, for any state or Union territory, the classes to be deemed socially and educationally backward for the purposes of the Constitution.
Q5. Did the ruling lead to any further constitutional change? Yes. Article 342A was subsequently amended by the Constitution (105th Amendment) Act, 2021.
Quick Revision
- Case: Jaishri Laxmanrao Patil v Union of India.
- Issue: Maharashtra's SEBC-based reservation for Marathas after the 102nd Amendment Act, 2018.
- Verdict: 3:2 majority — states lack power to identify SEBCs independently.
- 102nd Amendment Act, 2018 inserted Articles 338B, 342A and 366(26C).
- Article 342A: President notifies SEBCs for a state/UT by public notification.
- Article 366(26C): defines SEBCs with reference to Article 342A.
- Article 342A later amended by the 105th Amendment Act, 2021.
Sources
- The Constitution of India — official text, Ministry of Law and Justice
- Constitution (One Hundred and Second Amendment) Act, 2018 — legislative.gov.in
- Supreme Court of India — official judgment records
Further Reference
For deeper reading on this topic and the wider polity syllabus, these standard works are recommended:
- M. Laxmikanth, Indian Polity (McGraw Hill) — the standard UPSC handbook.
- D.D. Basu, Introduction to the Constitution of India (LexisNexis) — authoritative constitutional-law treatment.
- The Constitution of India — Bare Act — the official text.
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Constitutional provisions
Gives constitutional status to the National Commission for Backward Classes (NCBC); inserted by the 102nd Amendment Act, 2018.
President notifies, by public notification, the socially and educationally backward classes for a state or Union territory; later amended by the 105th Amendment Act, 2021.
Defines "socially and educationally backward classes" with reference to Article 342A.