Sadhana Singh Dangi v. Pinki Asati: Strengthening Merit-Based Horizontal Reservations in Public Service Selections

Introduction

The case of Sadhana Singh Dangi And Others v. Pinki Asati And Others (2021 INSC 907) was adjudicated by the Supreme Court of India on December 16, 2021. This landmark judgment addresses the intricate balance between vertical and horizontal reservations in the selection process for public service positions, specifically focusing on the selection of Assistant Professors by the Madhya Pradesh Public Service Commission (MPPSC). The primary parties involved were the petitioners Sadhana Singh Dangi and others, challenging the revised selection list issued by MPPSC, and the respondents Pinki Asati and others, representing the MPPSC and other entities.

Summary of the Judgment

The Supreme Court granted leave to hear appeals against the High Court's decision dated April 29, 2020, which had quashed the MPPSC's revised selection list for Assistant Professors. The central issue revolved around the allocation of seats under horizontal reservations—specifically, whether candidates from reserved categories (like OBC Women) who secured higher merit should be allocated seats in the general (unreserved) category based on merit or remain confined within their reserved category allocations.

The Supreme Court overturned the High Court's decision, thereby reinstating the revised selection list. The Court emphasized that horizontal reservations are compartmentalized and must not interfere with merit-based allocations in the general category. It affirmed that candidates from reserved categories who outperform their general category counterparts in merit should be allotted seats in their reserved categories without being downgraded to the general category, ensuring that reservations do not compromise meritocracy.

Analysis

Precedents Cited

The High Court's judgment under appeal extensively referenced several landmark Supreme Court decisions, including:

• Indra Sawhney v. Union of India (1992): Established the framework for reservations in India, emphasizing the balance between affirmative action and meritocracy.
• Anil Kumar Gupta v. State of U.P. (1995): Addressed the nuances of reservation policies, particularly the segregation between vertical and horizontal reservations.
• Rajesh Kumar Daria v. Rajasthan Public Service Commission (2007): Clarified the distinction between vertical and horizontal reservations, reinforcing that horizontal reservations should be additional to the vertical ones without overlapping.
• Public Service Commission, Uttaranchal v. Mamta Bisht (2010): Emphasized that candidates reserving under horizontal categories should not displace merit-based selections in general categories.
• Saurav Yadav v. State of Uttar Pradesh (2021): Reinforced the principle that merit should not be compromised by reservation policies and that candidates from reserved categories should not be downgraded to general categories based on merit standings.

These precedents collectively underscored the Supreme Court’s stance on ensuring that reservations enhance inclusivity without undermining merit-based selections.

Legal Reasoning

The Supreme Court delved into the statutory provisions underpinning the reservation system. Specifically, it analyzed:

• Section 4(4) of the 1994 Act: Prevents candidates from reserved categories who are selected on merit in open competitions from being adjusted against their reserved category quotas.
• Rule 3 of the 1997 Rules (as amended in 2000 and 2015): Mandates a 33% horizontal reservation for women across all reserved and unreserved categories.

The Court criticized the High Court of Madhya Pradesh’s "second view," which restricted horizontal reservation allocations to candidates within their vertical reservation categories, thereby allowing less meritorious candidates to occupy general seats over more meritorious reserved category candidates. The Supreme Court upheld the "first view," endorsed by several other High Courts, advocating that horizontal reservations should not impede merit-based allocations in the general category.

The distinction between vertical (social) and horizontal (additional) reservations was pivotal. While vertical reservations pertain to categories like SC, ST, and OBC, horizontal reservations encompass categories such as women and physically handicapped individuals and must be applied without infringing upon meritocracy.

Impact

This judgment reinforces the sanctity of merit in public service selections while maintaining the integrity of reservation policies. It ensures that:

• Reserved category candidates who are more meritorious can secure seats in the general category without being relegated to their reserved categories.
• Reservations remain an additional layer promoting inclusivity without compromising on the quality and competence of appointees.
• Future selection processes by public service commissions must meticulously adhere to these principles, ensuring that horizontal reservations do not disrupt merit-based allocations in general categories.
• Candidates and public service bodies gain clarity on the application of reservation laws, minimizing ambiguities and potential litigations.

Overall, the judgment fortifies the framework of reservations, promoting a balanced approach that honors both affirmative action and merit-based selection.

Complex Concepts Simplified

Vertical Reservation: Refers to reservation policies based on social categories like Scheduled Castes (SC), Scheduled Tribes (ST), and Other Backward Classes (OBC). It ensures representation from these groups in various public service positions.

Horizontal Reservation: An additional layer of reservation that cuts across all vertical categories. Examples include reservations for women, economically weaker sections, and physically handicapped persons. Unlike vertical reservations, horizontal reservations are not linked to specific social categories but are aimed at enhancing inclusivity across the board.

Merit List: A ranking of candidates based on their performance (typically in exams or assessments) used to determine eligibility and selection for positions.

General Category (UNR/UNRF): Refers to candidates who do not belong to any of the reserved categories. Seats designated as unreserved are open to all candidates based on merit.

Reserved Category (OBC(F), SC(F), ST(F)): Refers to reserved seats for specific social categories combined with horizontal reservations, such as gender (F for female).

Conclusion

The Supreme Court’s decision in Sadhana Singh Dangi And Others v. Pinki Asati And Others marks a significant reinforcement of the balance between reservation policies and meritocracy in India's public service selection processes. By upholding that horizontal reservations must not impede the merit-based allocation of general category seats, the Court ensures that affirmative action measures augment rather than compromise the principles of fairness and competence. This judgment provides clear guidance for future selections, ensuring that deserving candidates from all categories are accorded their rightful positions without diminishing the essence of merit-based selection.

Moreover, by rejecting the restrictive "second view" held by certain High Courts, the Supreme Court has unified the interpretation of reservation laws, fostering consistency and predictability in their application across India. This not only benefits the candidates by safeguarding their merit-based rights but also aids public service commissions in conducting transparent and equitable selection processes.