By – Gunika Razdan

Introduction

The concept of “quota within quota” refers to the subdivision of reserved quotas into smaller segments to ensure equitable access for disadvantaged subgroups within larger marginalized communities. This framework seeks to address disparities in the distribution of reservation benefits, particularly among Scheduled Castes (SCs), who are not a homogenous group but consist of diverse subgroups with varying socio-economic challenges.[1]

India’s reservation system was originally designed to uplift historically marginalized communities, including SCs and Scheduled Tribes (STs), by providing them access to education, public jobs, and political representation. While this framework has been instrumental in alleviating poverty and reducing inequalities, evidence suggests that benefits are unevenly distributed among SC subgroups. This can be explained through the instance wherein, economically and socially advanced SCs tend to dominate reserved opportunities, leaving more disadvantaged groups, such as Mazhabi Sikhs and Balmikis in Punjab, behind.[2]

Challenges to implementing “quota within quota” include the lack of caste certificates, which restricts SC households’ access to benefits, particularly in states like Uttar Pradesh and Bihar. Additionally, political influence in subgroup inclusion decisions and the potential introduction of a “creamy layer” within SCs risk undermining the policy’s intent.

To ensure equitable reservation policies, robust data collection and evidence-based decision-making are critical. Updated census data on caste disparities is essential to prevent reforms from being guided by outdated or incomplete evidence. By addressing intra-group disparities, “quota within quota” could enhance the reservation system’s ability to deliver social justice.[3]As there are also states like Tamil Nadu and Andhra Pradesh which conversely, report more uniform socio-economic progress among SC subgroups, reducing the need for such subdivisions.[4]

Historical Context and Graded Inequality

Dr. B.R. Ambedkar emphasized the “graded inequality[5]” inherent in the caste system, where even among the oppressed, some communities are more disadvantaged than others. This “graded hierarchy” has led to unequal access to the benefits of reservations within the Scheduled Castes, Scheduled Tribes, and Other Backward Classes. [6]For example, the Madiga community in Andhra Pradesh and Telangana has long argued that the Mala community benefits disproportionately from SC reservations.

However, the ideology of forming a quota within a quota faces various judicial challenges. In the landmark judgment of EV Chinnaiah v. State of Andhra Pradesh (2004),[7] the Supreme Court held that Scheduled Castes form a homogenous group and ruled sub-classification within SCs unconstitutional. Though, this decision is under review, as a seven-judge Constitution Bench reserved its judgment in February 2024 still posters to be questioning te basic grounds of the quota set-up.

As further, in contrast the Court has allowed sub-classification in the OBC category through the concept of the “creamy layer” (e.g., Indra Sawhney v. Union of India in 1992[8]). The same principle, however, has not been applied to SCs and STs, despite evidence of significant intra-group disparities.

The argument against blanket reservations is rooted in the persistence of caste-based discrimination, even among those who achieve economic mobility. Critics highlight that focusing only on economic upliftment overlooks the deep-seated social prejudices faced by marginalized groups.

Historical and Philosophical Foundations of Reservation Policies in India

 Evolution of Reservation Policies in India

Pre-Independence Developments

Over the course of Indian history, the caste system underwent changes, particularly during the Mughal and British rule. These periods of colonization diluted the traditional Varna system but perpetuated systemic inequality. During India’s freedom struggle, many leaders and reformers sought to uplift the marginalized sections of society, often referred to as the “lowest class.” This effort aimed to integrate these communities into the freedom movement and unite all Hindus.[9]

Mahatma Gandhi referred to these marginalized groups as “Untouchables” or “Harijans” (Sons of God),[10] while Dr. B.R. Ambedkar popularized the term “Dalits” to describe those oppressed by the caste system. These communities faced severe discrimination, exclusion from society, and denial of legal rights and basic amenities. They often lived outside residential areas and were subject to violence and harsh punishments for violating social norms. These injustices severely hindered their progress and laid the foundation for the introduction of reservation policies in India.

The demand for reservations began to take shape during the late 19th and early 20th centuries. In 1891, there was a major agitation in Kerala’s princely state of Travancore against the appointment of Tamil Brahmins over qualified locals to government jobs. In 1902, Shahu Maharaj of Kolhapur introduced reservations for non-Brahmins and backward classes in education. Similarly, the princely state of Mysore introduced reservations for backward castes in 1921 following a prolonged social justice movement.[11]

By 1932, the community’s demands for representation in legislatures and government jobs led to further polarization. Communities like the Ezhavas, Muslims, and some Christians sought representation, which culminated in community-based reservations on July 14, 1936. Quotas were allocated based on the numerical strength of these communities. In Travancore-Cochin State in 1952, this system was refined to include a 45% reservation, of which 10% was allocated to Scheduled Castes and Scheduled Tribes, and 35% to Other Backward Castes, including Muslims, Ezhavas, and others.

Legally, the reservation system traces its origins to the Government of India Act of 1919, enacted during World War I. While this Act introduced significant reforms, it faced opposition, particularly regarding the separate electorates for Muslims introduced by the Minto-Morley Act of 1909. The Simon Commission in 1927 examined these reforms and recommended a united electorate with reserved seats for disadvantaged classes.

The Round Table Conferences of the 1930s further discussed representation for the oppressed classes. Dr. B.R. Ambedkar demanded separate electorates for these groups, but this was opposed by Mahatma Gandhi and the Congress. The conflict led to the Communal Award of 1932, granting separate representation to minorities and Dalits, which was eventually resolved by the Poona Pact. This agreement reserved seats for disadvantaged castes within the Hindu electorate.

The Government of India Act of 1935 institutionalized these provisions, and by 1942, the Viceroy’s Executive Council recommended an 8.5% reservation for Scheduled Castes in civil services, with Dr. Ambedkar becoming a council member. These developments laid the groundwork for the reservation policies implemented in independent India.

Post-Independence Developments

After independence, Dalits demanded equal opportunities in education, employment, and development, leading to the formal recognition of SCs and STs in the Indian Constitution. The reservation policy aimed to grant equal rights to these marginalized communities for a limited time to facilitate their progress.

The Constitution of India, adopted in 1950, provided reservations for SCs and STs but initially excluded converted castes. By the 1990s, Sikhs and Buddhists were included, but Muslims and Christians were not. The First Amendment in 1951 legalized caste-based reservations. In 1956, after state reorganization, changes to the quota system expanded reservations to over 70 backward classes, 78 SCs, and 38 STs, increasing OBC reservation to 40%, raising the total to 50%.

In 1990, the Mandal Commission recommended 27% reservation for Other Backward Classes (OBCs). The Supreme Court ruled in 1992 that total reservations could not exceed 50%, but in 2019, the 10% reservation for economically weaker upper castes was introduced.

Philosophical Foundations

Social Justice and Equity in India’s Constitution

Social justice and equity are central to the Indian Constitution. The Preamble, along with Articles 14, 15, and 16, establishes the core principles of equality, non-discrimination, and equal opportunities in education, employment, and social life. Article 14 ensures equality before the law, while Article 15 prohibits discrimination on the grounds of religion, race, caste, sex, or place of birth. Article 16 further guarantees equality of opportunity in matters of public employment. Additionally, Article 46 directs the State to promote the educational and economic interests of the backward classes, protecting them from exploitation. These provisions form the bedrock of India’s commitment to social justice.

Ambedkar’s Vision

Dr. B.R. Ambedkar’s vision was centred on correcting the centuries-long caste-based oppression faced by Dalits and other marginalized groups. He sought to provide constitutional safeguards that would empower these communities. His belief in social justice led to the inclusion of reservations for Scheduled Castes (SCs), Scheduled Tribes (STs), and Other Backward Classes (OBCs) to ensure their representation and access to resources like education, employment, and political participation. Ambedkar viewed reservations as a temporary measure to level the playing field and correct the injustices perpetrated by the caste system.

Critiques of Blanket Quotas

While the reservation system has been instrumental in promoting social equality, critiques of blanket quotas have emerged over time. A key concern is the potential inequity within the reserved categories. Within these groups, disparities exist, and some individuals may be relatively more advantaged than others, raising questions about whether they should benefit from reservations. Furthermore, critics argue that the reservation system needs to be aligned with the current socio-economic realities.

Simply granting reservations based on caste may overlook other significant factors such as income, education level, and social mobility. Thus, aligning the reservation criteria with these realities could better target the genuinely disadvantaged members of society.[12] By addressing these critiques, the reservation policy could evolve to better serve the goal of equitable development for all.

Case Studies of Sub-Categorization in India

The Justice Rohini Commission, formed in 2017, was tasked with addressing the disparities in the distribution of reservation benefits among the Other Backward Classes (OBCs) in India. The commission’s findings revealed that 97% of reserved jobs and seats were taken by just 25% of OBC sub-castes, leaving many communities underrepresented. Based on this, the commission recommended dividing OBCs into four sub-categories to ensure a more equitable distribution of benefits.[13]

Several states have already implemented sub-categorization frameworks, such as Tamil Nadu, which follows a 69% reservation system with detailed sub-categorization, and Andhra Pradesh and Karnataka, which have multiple OBC categories (e.g., A, B, C, D). A notable example of this approach in action is Bihar’s “Mahadalit Vikas Mission”, which focuses on uplifting the most disadvantaged sub-castes within the Scheduled Castes (SC) category.[14]

These initiatives align with the Rohini Commission’s findings, demonstrating that targeted sub-categorization can address intra-group inequality. Bihar’s success in identifying and assisting the most backward sub-castes serves as a model for other states to create more inclusive and effective policies for equitable distribution of benefits among OBCs.

Challenges and Criticisms of Blanket Reservations in India

India’s reservation system aims to uplift marginalized communities, but disparities within Scheduled Castes (SCs) have led to dominant sub-castes monopolizing benefits, leaving smaller sub-castes underserved. Sub-categorization has emerged as a solution to ensure equitable distribution, but it introduces complex legal, administrative, and social challenges. Recent Supreme Court rulings and state-level efforts reflect a shift toward addressing these inequalities, though concerns remain about deepening divisions and deviating from the original intent of social justice policies.

The overrepresentation of dominant sub-castes within Scheduled Castes (SCs) in India has led to significant inequality in accessing reservation benefits. Sub-castes like Jatav. in Uttar Pradesh and Mahars in Maharashtra have cornered most of the opportunities meant for marginalized Dalits. Smaller, disadvantaged sub-castes such as Madigas in Andhra Pradesh and Telangana, or Arunthathiyars in Tamil Nadu, have struggled to gain access to these benefits. To address this, some states have implemented sub-categorization within SCs, aiming to ensure equitable distribution of opportunities. The Supreme Court verdicts on sub-categorization is expected to bring transformative changes, empowering marginalized sub-castes to demand fair representation and opportunities.[15][16]

The Supreme Court’s recent ruling on caste sub-classification underlined significant administrative and legal complexities. It allowed states to create separate quotas for more marginalized groups within the SC and ST categories, aiming to address disparities. However, implementation remains challenging at both state and central levels due to the intricacies of identifying and categorizing the most marginalized within these groups.

Legal debates about reservation caps, especially the 50% ceiling established by the Indra Sawhney case (1992), further complicate matters. The ruling also highlighted ongoing controversies, such as Maharashtra’s Maratha quota, which pushes the limits of this cap, intensifying legal and political resistance to exceeding it. These challenges reflect broader tensions around affirmative action in India, questioning whether sub-classification might perpetuate inequalities rather than mitigate them. Additionally, while aiming to empower the most disadvantaged, such measures risk deepening divisions within already marginalized communities and reducing the social justice focus of the original reservation policies.[17]

Policy Recommendations for India

The Supreme Court’s recent judgment State of Punjab v. Davinder Singh (2024)[18]on sub-classification within SCs and STs underscores the need for evidence-based policymaking in India’s reservation system. The Court recognized that SCs and STs are not homogeneous groups, and intra-group disparities persist, with certain communities benefiting disproportionately from reservation benefits. Strengthening data collection, such as through a caste census, is crucial to address these disparities. Additionally, institutionalizing periodic reviews of reservation policies can ensure that the most marginalized communities receive adequate support. The judgment paves the way for more effective and equitable distribution of reservation benefits, emphasizing the need for continuous, data-driven reforms.[19]

Balancing equity and efficiency in India’s reservation system requires addressing the complex needs of marginalized communities while ensuring the effective implementation of policies. Simplifying administrative procedures is essential for streamlining the process, making it more transparent and accessible to those who need it most. By reducing bureaucratic hurdles, the system can more efficiently allocate benefits to the disadvantaged, ensuring that reservations reach the intended beneficiaries without unnecessary delays. Additionally, introducing flexible mechanisms to address overlapping disadvantages—such as those experienced by women or disabled individuals within reserved groups—can create a more inclusive framework. This approach ensures that reservations not only cater to broader categories like Scheduled Castes but also prioritize individuals facing compounded barriers to social mobility. Such a system would foster social justice while maintaining efficiency, ultimately creating a more equitable society.

Conclusion

The “quota within quota” framework represents a nuanced evolution in India’s reservation policy, addressing deep-seated inequalities within marginalized communities. By recognizing intra-group disparities, this approach seeks to redistribute the benefits of affirmative action more equitably, uplifting sub-castes and individuals who have historically remained underserved. Initiatives like Bihar’s “Mahadalit Vikas Mission” and Punjab’s sub-categorization efforts exemplify how targeted interventions can drive social equity and serve as scalable models for other states.

However, the success of such measures depends on their implementation. Without robust data, transparent processes, and safeguards against political manipulation, sub-classification risks perpetuating new hierarchies or further fragmenting marginalized groups. The anticipated judicial interpretations, such as the review of the E.V. Chinnaiah judgment, will provide critical legal clarity, ensuring these efforts remain aligned with India’s constitutional vision of justice and equality.

A progressive step forward would be adopting an intersectional lens to reservations. By addressing overlapping disadvantages—such as gender, disability, and regional inequalities—policymakers can ensure that affirmative action frameworks reflect the diverse realities of marginalization. Gender-specific quotas, regional prioritization for rural communities, and disability-inclusive sub-policies are examples of how the system can evolve to better serve its goals.

Ultimately, for reservations to remain a powerful tool of social justice, they must not only correct historical injustices but also adapt to emerging inequalities. India’s commitment to equity must be rooted in evidence-based, inclusive, and flexible reforms that empower the most vulnerable. By achieving this balance, the reservation system can continue to drive transformative change, fostering equitable growth and empowering marginalized communities to fully participate in the nation’s progress.

References

1. Indira Sawhney v. Union Of India & Ors – Lnind 1999 Sc 1139 (1992) Supp 3 Scc 2101999 (7) Scale 411air 2000 Sc 498jt 1999 (9) Sc 557lnind 1999 Sc 1139
2. E.V.Chinnaiah Versus State of Andhra Pradesh and others LNIND 2004 SC 1137
3. State of Punjab v. Davinder Singh, 2024 INSC 562
4. Patnaik, Sushovan. “Five Must-Reads on Sub-Classification within Reserved Categories.” Supreme Court Observer, 22 Feb. 2024, https://www.scobserver.in/journal/debating-oppression-five-must-reads-on-sub-classification-within-reserved-categories/.
5. Pal, Kanishka Bhowmick, Indraneel Dasgupta, Sarmistha. Within-Group Inequality and Caste-Based Crimes in India. Oct. 2024.
6. Govindhraj. “(PDF) An Evaluation of the Reservation System in India.” ResearchGate, 2023, https://www.researchgate.net/publication/375866518_An_Evaluation_of_the_Reservation_System_in_India.
7. Pandey, Rakesh. “Entropic Analysis of Reservation Policy of Government of India.” ResearchGate, 2023, https://www.researchgate.net/publication/374132789_Entropic_Analysis_of_Reservation_Policy_of_Government_of_India.
8. Bhagwan Das. “Moments in a History of Reservations.” Economic and Political Weekly, vol. 35, no. 43/44, 2000, pp. 3831–34. JSTOR, http://www.jstor.org/stable/4409890. Accessed 9 Jan. 2025.
9. Gogoi, Dr Paban. “Reservation Politics in India: An Analysis of the Indian  Reservation System.” Journal of Research in Humanities and Social Science, 2023.
10. SINGH, ASHISH, et al. “Exclusion within the Excluded: The Economic Divide within Scheduled Castes and Scheduled Tribes.” Economic and Political Weekly, vol. 50, no. 42, 2015, pp. 32–37. JSTOR, http://www.jstor.org/stable/44004068. Accessed 9 Jan. 2025.
11. Sharma, Mansi. “RESERVATION POLICY IN INDIA SCOPE,  DEVELOPMENT, HISTORY AND EMPLOYMENT  RIGHTS.” International Journal of Human Rights Law Review , 2023.
12. Department of Economic Affairs. “Economic Survey (2003-04).” Indian Budget, 2004.
13. National Commission for Backward Classes. Sub-Categorisation under OBC’s. 2015.

1. Jodhka, Surinder S. “Need to Look beyond Identities to Remove Inequalities.” The Tribune, 23 Aug. 2024, https://www.tribuneindia.com/news/comment/need-to-look-beyond-identities-to-remove-inequalities.
2. Standard, Business. “Business Standard.” Business Standard, 26 Oct. 2023, https://www.business-standard.com/india-news/rohini-commission-decoded-understanding-sub-categorisation-of-obcs-123102600760_1.
3. Parthasarathy, Malavika. “Creamy Layer: Court in Review.” Supreme Court Observer, 26 Mar. 2022, https://www.scobserver.in/journal/creamy-layer-court-in-review.
4. Damera, Suman. “SC Sub-Quota Verdict: Revisiting the Long-Drawn Struggle for Reservation Justice.” The Wire, The Wire, 2024, https://thewire.in/rights/sc-sub-quota-verdict-revisiting-the-long-drawn-struggle-for-reservation-justice.
5. Bodwal, Harsh. “Unpacking The SC Verdict On Caste Sub-Classification.” Feminism in India, 6 Aug. 2024, https://feminisminindia.com/2024/08/06/breaking-down-barriers-or-reinforcing-divisions-the-supreme-courts-verdict-on-caste-sub-classification.
6. “Social Progress Index: States and Districts of India.” Social Progress Imperative, https://www.socialprogress.org/thematic-webpages/social-progress-index-states-and-districts-of-india. Accessed 11 Jan. 2025.

• Indulia, Bhumika. “Decoding Sub-Classification in SCs.” SCC Times, 23 Sept. 2024, https://www.scconline.com/blog/post/2024/09/23/decoding-sub-classification-in-scs.

• “The Ambedkar-Gandhi Debate on Untouchability.” The Indian Express, 26 Dec. 2024, https://indianexpress.com/article/upsc-current-affairs/upsc-essentials/the-ambedkar-gandhi-debate-on-untouchability-9742756/.

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[1] Jodhka, Surinder S. “Need to Look beyond Identities to Remove Inequalities.” The Tribune, 23 Aug. 2024, https://www.tribuneindia.com/news/comment/need-to-look-beyond-identities-to-remove-inequalities.

[2] Department of Economic Affairs. “Economic Survey (2003-04).” Indian Budget, 2004.

[3] Pal, Kanishka Bhowmick, Indraneel Dasgupta, Sarmistha. Within-Group Inequality and Caste-Based Crimes in India. Oct. 2024.

[4] “Social Progress Index: States and Districts of India.” Social Progress Imperative, https://www.socialprogress.org/thematic-webpages/social-progress-index-states-and-districts-of-india. Accessed 11 Jan. 2025.

[5] B. R. AMBEDKAR.  “The ANNIHILATION OF CASTE.”, 15 May. 1936. 

[6] Patnaik, Sushovan. “Five Must-Reads on Sub-Classification within Reserved Categories.” Supreme Court Observer, 22 Feb. 2024, https://www.scobserver.in/journal/debating-oppression-five-must-reads-on-sub-classification-within-reserved-categories/.

[7] E.V.Chinnaiah Versus State of Andhra Pradesh and others LNIND 2004 SC 1137

[8] INDIRA SAWHNEY v UNION OF INDIA & ORS – LNIND 1999 SC 1139 (1992) Supp 3 SCC 2101999 (7) SCALE 411AIR 2000 SC 498JT 1999 (9) SC 557LNIND 1999 SC 1139

[9] Gogoi, Dr Paban. “Reservation Politics in India: An Analysis of the Indian  Reservation System.” Journal of Research in Humanities and Social Science, 2023.

[10] “The Ambedkar-Gandhi Debate on Untouchability.” The Indian Express, 26 Dec. 2024, https://indianexpress.com/article/upsc-current-affairs/upsc-essentials/the-ambedkar-gandhi-debate-on-untouchability-9742756/.

[11] Sharma, Mansi. “Reservation Policy In India Scope, Development, History And Employment Rights.” International Journal of Human Rights Law Review, 2023.

[12] Bhagwan Das. “Moments in a History of Reservations.” Economic and Political Weekly, vol. 35, no. 43/44, 2000, pp. 3831–34. JSTOR, http://www.jstor.org/stable/4409890. Accessed 9 Jan. 2025.

[13] National Commission for Backward Classes. Sub-Categorisation under OBC’s. 2015.

[14] Standard, Business. “Business Standard.” Business Standard, 26 Oct. 2023, https://www.business-standard.com/india-news/rohini-commission-decoded-understanding-sub-categorisation-of-obcs-123102600760_1.

[15] Damera, Suman. “SC Sub-Quota Verdict: Revisiting the Long-Drawn Struggle for Reservation Justice.” The Wire, The Wire, 2024, https://thewire.in/rights/sc-sub-quota-verdict-revisiting-the-long-drawn-struggle-for-reservation-justice.

[16] Bodwal, Harsh. “Unpacking The SC Verdict On Caste Sub-Classification.” Feminism in India, 6 Aug. 2024, https://feminisminindia.com/2024/08/06/breaking-down-barriers-or-reinforcing-divisions-the-supreme-courts-verdict-on-caste-sub-classification.

[17] Govindhraj. “(PDF) An Evaluation of the Reservation System in India.” ResearchGate, 2023, https://www.researchgate.net/publication/375866518_An_Evaluation_of_the_Reservation_System_in_India.

[18] State of Punjab v. Davinder Singh, 2024 INSC 562

[19] Indulia, Bhumika. “Decoding Sub-Classification in SCs.” SCC Times, 23 Sept. 2024, https://www.scconline.com/blog/post/2024/09/23/decoding-sub-classification-in-scs.