Case Title: CHEBROLU LEELA PRASAD RAO & ORS. V. STATE OF A.P. & ORS.
The Supreme Court ruled that it is unconstitutional to reserve all teaching positions at schools in "Scheduled Areas" for members of Scheduled Tribes.
The government order affirming absolute reservation for Scheduled Tribe teachers, which was signed by the governor of the State of Andhra Pradesh, was overturned by a five-judge Constitutional bench led by Justice Arun Mishra. The court also imposed costs on the governments of Telangana and Andhra Pradesh and demanded explanations from them for exceeding the 50% cap on reservations.
After an appeal was filed against the Andhra Pradesh High Court ruling upholding the government order establishing the previously mentioned 100% reservation, the matter made it to the Apex Court.
The court further held that the existing appointments made in excess of the 50% reservation shall survive but cease to be effective in the future, providing relief to those who had already been appointed based on the government order. The court also interpreted the judgement prospectively and not "retrospectively."
The petitioner relied on Vinayakrao Gangaramji Deshmukh v. PC Agrawal and R. Chitralekha v. State of Mysore, arguing that it was discriminatory because it not only affected candidates in the open category but also those in other reserved categories and that the percentage of reservation allowed by Article 16(4) should not be higher than 50%.
The Court emphasised that in addition to scheduled tribes, scheduled castes, and other scheduled tribes settled in the said area also form part of the population in the scheduled territories but are not included in the notice.
The Court in this case heavily relied on the ruling of Indira Sawnhey v. Union of India, which stated that reservations are legally legitimate as long as they do not exceed 50%. The court stated:-
"No law mandates that only tribal teachers can teach in the scheduled areas; thus, the action defies the logic. Another reason given is the phenomenal absenteeism of teachers in schools. That could not have been a ground for providing 100 per cent reservation to the tribal teachers in the areas. It is not the case that incumbents of other categories are not available in the areas."
"The reason assigned that reservation was to cover impetus in the scheduled areas in the field of education and to strengthen educational infrastructure is also equally bereft of substance. By depriving opportunity to others, it cannot be said that any impetus could have been given to the cause of students and effective education, and now that could have been strengthened. The provisions of 100 per cent reservation are ignoring the merit. Thus, it would weaken the educational infrastructure and the merit, and the standard of education imparted in the schools. The ideal approach would be that teachers are selected based on merit", added the bench.