Supreme Court Reinforces State Authority in Reservation Policies: Analysis of State Of Punjab v. Anshika Goyal And Others

Introduction

The Supreme Court of India, in the landmark case of State Of Punjab v. Anshika Goyal And Others (2022 INSC 94), addressed pivotal issues surrounding reservation policies in educational institutions. The case arose when the High Court of Punjab and Haryana directed the State of Punjab to implement specific reservations for children and grandchildren of terrorist-affected persons, Sikh riots-affected persons, and sportspersons in private unaided non-minority medical and dental institutions. Additionally, the High Court mandated an increase in the sports quota from 1% to 3% in government medical and dental colleges. Dissatisfied with these directives, the State of Punjab appealed to the Supreme Court, challenging the High Court's intervention in state policy-making.

Summary of the Judgment

The Supreme Court, after thorough deliberation, allowed the appeals filed by the State of Punjab, thereby quashing the High Court's directions. Specifically, the Supreme Court set aside the directive to increase the sports quota from 1% to 3%, emphasizing the State's discretion in policy formulation. However, regarding the reservation/quota for children and grandchildren of terrorist-affected persons and Sikh riot-affected persons in private unaided non-minority medical and dental institutions, the courts deemed the issue academic, as the State had already complied with these directives for the academic year 2021-22.

Analysis

Precedents Cited

The Supreme Court referenced several key judgments to support its stance:

Gulshan Prakash v. State of Haryana (2010) 1 SCC 477: Established that courts cannot issue a mandamus compelling the State to implement reservation policies.
Central Bank of India v. SC/ST Employees Welfare Assn. (2015) 12 SCC 308: Reinforced that Articles 15 and 16 are enabling provisions, permitting but not mandating the State to create reservations.
Suresh Chand Gautam v. State of U.P. (2016) 11 SCC 113: Clarified that mandamus cannot be used to direct States to frame or modify reservation policies.
Mukesh Kumar v. State of Uttarakhand (2020) 3 SCC 1: Affirmed that States retain exclusive authority over reservation policies and courts cannot mandate specific percentages.

Legal Reasoning

The Supreme Court underscored the constitutional principle that reservation policies fall under the purview of the State Government's discretion. Citing the aforementioned precedents, the Court emphasized that Articles 15(4), 15(5), 16(4), and 16(4-A) of the Constitution are enabling in nature, providing States the authority to implement reservations as they deem fit. The High Court's issuance of a writ of mandamus to alter the State's reservation policy was deemed an overreach, infringing upon the legislative domain reserved for the State.

Impact

This judgment has significant implications:

Affirmation of State Sovereignty: Reinforces the principle that States have the autonomy to design and implement their reservation policies without judicial intervention unless constitutional limits are breached.
Limits on Judicial Mandamus: Clarifies that courts cannot compel States to make specific policy decisions, maintaining a clear boundary between judiciary and executive functions.
Future Reservation Policies: Sets a precedent that while States can fashion reservations for various categories, the extent and nature of such reservations remain within their legislative competence.

Complex Concepts Simplified

Mandamus

A legal remedy in the form of an order from a superior court to a lower court, public authority, or governmental body to perform a duty that is mandated by law. In this case, the High Court issued a mandamus directing the State to implement specific reservations, which the Supreme Court ultimately quashed.

Reservation Policies

These are affirmative action measures designed to improve the representation of historically disadvantaged groups in education and employment. The Constitution of India permits States to implement such policies to promote social justice.

Conclusion

The Supreme Court's decision in State Of Punjab v. Anshika Goyal And Others reinforces the autonomy of State Governments in crafting reservation policies tailored to their unique socio-political contexts. By quashing the High Court's attempt to mandate specific reservation percentages, the Court upheld the constitutional principle of State discretion under Articles 15 and 16. This judgment demarcates the boundaries of judicial intervention, ensuring that substantive policy decisions remain within the legislative and executive domains of the State, thereby maintaining the balance of power envisioned by the Constitution.