The Karnataka High Court on Monday struck down the provisions of the Karnataka Scheduled Castes and Scheduled Tribes (Reservation of Seats in Educational Institutions and of Appointments or Posts in the Services under the State) Act, 2022, which increased reservation for Scheduled Castes (SCs) from 15 to 17 percent and for Scheduled Tribes (STs) from 3 to 7 percent [Mahendra Kumar Mitra & others Vs Union of India & others].

A bench of Chief Justice Vibhu Bakhru and Justice K S Hemalekha held that Section 3 of the Act, insofar as it took the aggregate reservation beyond the 50 percent ceiling, violated Articles 14 and 15 of the Constitution.

The Court also struck down Section 4, which provided for the enhanced reservation in State government services.

The Court passed the decision on two petitions challenging the constitutional validity of the legislation, which increased the overall reservation for SCs, STs and other backward classes from 50 to 56 percent.

“Section 3 of the Act, insofar as it takes the aggregate reservation beyond the ceiling of 50%, is struck down as it violates Articles 14 and 15 of the Constitution,” the Court held.

One of the petitions was filed by Mahendra Kumar Mitra, State President of the Dr Ambedkar Scheduled Castes Federation. Another Petition was filed by Sagar H R, Prajwal Kumar D and Purushotham Gowda G M, graduates in civil engineering who had applied for appointment to the post of Assistant Engineer (Civil) in the Bruhat Bengaluru Mahanagara Palike (BBMP).

The petitioners challenged the increase in reservation in State government appointments, contending that the legislation breached the constitutional limit on reservation and affected the guarantee of equality and equal opportunity.

The Act, which received the Governor's assent on January 11, 2023, was published in the Karnataka Gazette on January 12, 2023, and was deemed to have come into force from November 1, 2022.

Under Section 3, reservation for SCs and STs in admissions to educational institutions was increased to 17 percent and 7 percent, respectively.

Section 4 increased their reservation in State government services from 15 to 17 percent and from 3 to 7 percent, respectively.

Since the 32 percent reservation for other backward classes remained unchanged, the overall reservation rose from 50 to 56 percent.

The legislation followed recommendations and reports concerning the representation of SCs and STs, including those associated with the Justice (Rtd) Nagamohan Das Commission and the committee headed by former High Court judge Justice Subhash B. Adi.

Senior advocate Prof, Ravivarma Kumar, appearing for the State of Karnataka, defended the legislation and argued that the material collected by various committees justified the increase.

The State relied on the reports of the Nagamohan Das Commission, the Adi Committee and the Ratnaprabha Committee to contend that SCs and STs continued to be inadequately represented and that the existing reservation framework did not adequately reflect demographic changes.

The State argued that the population of SCs and STs had increased substantially over the years, while their reservation had remained unchanged for decades.

It also contended that the reports demonstrated the marginalisation of several communities and the need to provide adequate and effective representation in public employment.

The State further argued that the 50% ceiling should not be treated as an inflexible rule in circumstances warranting an exception.

Rejecting the State's contention that the demographic composition of Karnataka justified the enhanced quota, the High Court reiterated that the 50% ceiling was intended to maintain a balance between affirmative action and the constitutional guarantee of equality.

The bench noted the State's argument that more than 90% of Karnataka's population are SCs, STs and other backward classes and that reservation should reflect their proportion of the population.

Rejecting that submission, the Court observed,

“To accept the said contention would be destructive of the principle of equality enshrined under the Constitution.”

The Court explained that the 50% ceiling circumscribed the State's power to provide reservation, irrespective of the numerical strength of backward classes

The Court also held that evidence showing inadequate representation of SCs and STs could support a case for reservation within the constitutional framework, but would not automatically permit the State to exceed the ceiling.

The State relied on reports examining the representation and socio-economic conditions of SCs and STs to establish the need for increased reservation.

The Court, however, distinguished between evidence supporting affirmative action and evidence establishing circumstances warranting a departure from the 50% ceiling.

It noted that the reports might support measures to ensure that reservation benefits reached marginalised communities, including through internal reservation, but did not by themselves establish a legal basis to exceed the overall limit.

The bench held that the exception for extraordinary circumstances could not be invoked merely because certain communities were inadequately represented or their population had increased.

The Court also observed that the collection of quantifiable data concerning backwardness and inadequate representation did not, by itself, permit the State to breach the 50% ceiling.

The High Court also examined whether the State had complied with its constitutional obligation to consult the National Commission for Scheduled Castes and the National Commission for Scheduled Tribes before taking a major policy decision affecting those communities.

The bench held that reservation policy constituted a major policy matter and that consultation with the two commissions was mandatory under Article 338(9) and Article 338A(9) of the Constitution.

The State had relied on letters dated December 10, 2025, and January 20, 2026, in support of its case on consultation. The Court noted that the communications were issued nearly three years after the legislation was enacted and after its validity had been challenged before the High Court.

The bench held that such subsequent correspondence could not satisfy the constitutional requirement.

“Consultation, to be meaningful and effective, must precede the decision” the Court observed.

It further held that the constitutional requirement was not confined to policy decisions that adversely affected SCs or STs, but extended to all major policy matters affecting them.

The Court concluded that the State could not substitute post-enactment correspondence for prior, meaningful consultation with the commissions.

Senior Advocate P S Rajagopal and advocate Vinayaka S Pandit appeared for petitioners.

Senior advocates Prof. Ravivarma Kumar and Ruben Jacob, Advocates Sidharth Baburao, Ashwini O, Inchara H M, Ranjutha Ravindra, Somashekar, Kushal V S, K M Prakash, B L Sanjeev and Central Government Standing Counsel Harsha P. Banad appeared for respondents.

Senior Adocate Udaya Holla, advocates Vivek Holla Pavan Kumar N, Vijay Kumar V B appeared for applicants.

[Read Judgment]