Supreme Court allows Manipur University to change quota in admissions as per State reservation policy

The Supreme Court recently upheld a Manipur High Court order allowing Manipur University to change its reservation quota for various categories in line with State policy (Shri Kshetrimayum Maheshkumar Sing & Anr v. Manipur University & Ors).

. The Court thus allowed the quota for Scheduled Caste (SC) candidates to change from 15 per cent to 2 per cent, for Scheduled Tribe (ST) candidates from 7.5 per cent to 31 per cent, and that of Other Backward Castes (OBC) candidates from 27 per cent to 17 per cent.

. A Bench of Justices Hima Kohli and L Nageshwar Rao observed that states lying in the North East have a predominantly tribal population and that Central educational institutes in the region would be unable to reduce seats for SCs and STs to accommodate the 27 per cent reservation for the OBC category.

"...University was right in reverting back to the position obtaining immediately before the commencement of the Reservation Act by reserving seats in respect of ST, SC and OBC candidates, pegged at 31%, 2% and 17% respectively which was in consonance with the Manipur State Reservation Policy," the Court held.

Manipur University was established in 1980 as a State University and hence was following the State reservation policy of 2 per cent, 31 per cent and 17 per cent reservation for SCs, STs and OBCs respectively. In 2005, the University was converted into a Central University. It continued following the same scheme of reservation till the Central Educational Institutions (Reservation in Admission) Act of 2006 was introduced.

Following that, from the academic year 2009-10 onwards, the University changed its policy to providing 15 per cent, 7.5 per cent and 27 per cent reservation in admission to SCs, STs and OBCs candidates respectively.

. An amendment to the 2006 Act was brought about in 2012, post which the University reverted to the scheme that existed before the principal Act was passed.

"The two provisos inserted in Section 3 of the Parent Act are nothing but a recognition of the demography of the North Eastern States covered under the umbrella of “Specified north eastern region” which have a substantial tribal population," the Court held.

Candidates belonging to SC category challenged this move before the High Court, which declined to interfere in the matter. On appeal, a Division Bench could not be constituted, as result of which, the matter was heard by the Meghalaya High Court. This High Court remanded the matter to the single-judge of the Manipur High Court for consideration afresh and called upon the Court to examine and decide the percentage of reservation for SC, ST and OBC categories in the light of the amendment. The High Court upheld the change in reservation quota, prompting the appellants to approach the Supreme Court.

. Advocate Punam Kumari appeared for the appellants while Advocates Ashutosh Dubey and Shivendra Dwivedi appeared for Manipur University. Additional Solicitor General Sanjay Jain appeared for the Central government.

. [Read Judgment]

Supreme Court allows Manipur University to change quota in admissions as per State reservation policy

Pranshu Bharti

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