Supreme Court Clarifies that Article 341 Provides Constitutional Identity, Not Homogeneity, for Scheduled Castes

The Supreme Court recently ruled that Article 341 of the Indian Constitution does not establish a 'deeming fiction' of a homogeneous class but instead grants a 'constitutional identity' to Scheduled Castes (SCs). In a 6:1 decision, the 7-judge Constitution Bench affirmed the validity of sub-classifying SCs, stating that Article 341's role is to legally recognize the communities identified as Scheduled Castes without implying uniformity among them.

Chief Justice of India DY Chandrachud, along with Justices BR Gavai, Vikram Nath, Bela Trivedi, Pankaj Mithal, Manoj Misra, and Satish Chandra Sharma, delivered the judgment. The bench held that Article 341 only creates a class for affirmative action purposes, distinguishing SCs from the rest of the population, but does not necessitate viewing them as a homogenous group.

The Court addressed three key questions: (1) Whether Article 341 creates a 'deeming fiction'; (2) If so, does this fiction imply that the SCs are a uniform class that cannot be further divided; and (3) The scope of Article 341(2) regarding such a legal fiction.

Under Article 341(1), the President can designate certain groups as Scheduled Castes in any State or Union Territory, a process done in consultation with the Governor and publicly notified. Article 341(2) allows Parliament to include or exclude groups from this list through legal enactment, but such a presidential notification cannot be altered by subsequent notifications.

The Court noted that the phrase “deemed to be” in Article 341 does not necessarily create a legal fiction. Instead, it often means "regarded as being." A legal fiction, according to the Court, involves treating something as true for legal purposes, even if it is not factually so.

The Court established two principles for interpreting legal fictions: (1) They should be confined to their specific purpose and not extended beyond it; and (2) Their effects should cover the logical consequences of their creation. However, a legal fiction cannot create presumptions for specific legal outcomes but only for the facts leading to those outcomes.

The Court clarified that Article 341 does not create a legal fiction but rather outlines the process for officially recognizing Scheduled Castes. It emphasized that the term 'deemed' in this context provides legal recognition rather than an artificial construction.

Additionally, the Court corrected the interpretation in the earlier case of Punit Rai v. Dinesh Chaudhary, where it was mistakenly suggested that Article 341 creates a legal fiction. The Court stressed that the use of "deemed" in Article 341 ensures that designated castes receive legal recognition as Scheduled Castes but does not imply a uniformity among them.

The decision also overturned the earlier ruling in E.V. Chinnaiah v. State of Andhra Pradesh, which incorrectly construed the essence of the NM Thomas case. The Court clarified that Scheduled Castes are not a homogenous class but can be further classified based on reasonable criteria.

The Court emphasized that Article 341(1) and (2) have specific restrictions: a caste recognized as Scheduled Caste in one state does not automatically have the same status in another, and only Parliament can modify the list, not the President or state governments.

Finally, the Court noted that Dr. B.R. Ambedkar's intent was to limit modifications to the list solely to Parliament to prevent political interference.

For further details on the judgment, please refer to the case: State of Punjab and Ors. v. Davinder Singh and Ors., C.A. No. 2317/2011.