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INTERNAL RESERVATION FOR ECONOMICALLY WEAKER SECTIONS: IS SUPREME COURT OF INDIA DONE INJUSTICE TO SOCIAL JUSTICE
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INTERNAL RESERVATION FOR ECONOMICALLY
WEAKER SECTIONS: IS SUPREME COURT OF INDIA DONE INJUSTICE TO SOCIAL JUSTICE
Abstract
The concept of reservation has been a
matter of debate for many decades in India. Initially reservation was
introduced to uplift the Scheduled Caste, Scheduled Tribes and followed by
backward classes of citizens in India. Nowadays, it has been extended to many
citing the reason that there are not adequately represented in the matter of
education, public employment etc., The very purpose of reservation itself is to
ensure the social justice among all sections of society. Dr.B.R.Ambedkar had
strongly believed that equality of opportunity may not be possible without
reservation for those who had faced a historical disadvantage. The internal
reservation for economically weaker sections for admission to Central
Government run educational institutions and private educational institutions and
for employment in Central Government jobs except for minority educational
institutions has raised the serious questions about very foundation of
reservation itself. There is no doubt that reservation for socially and
educationally weaker sections have guaranteed by the Constitution of India as
it is considered as affirmative action and reasonable for the poor and down
trodden. The ten percent reservation for economically weaker sections through
the 103rd Amendment of the Constitution is not beyond the debate and
criticism and resulted in knocking the door of the Supreme Court to nullify the
same but the Supreme Court of India decided in other way round. The moot
question before the society is that whether ten percent reservation is
reasonable and justifiable and whether Supreme Court of India has derailed from
ensuring the social justice or would it really a threat to downtrodden people.
In this paper, root cause behind the internal reservation for economically
weaker sections and applying the different yardstick by Supreme Court of India
while deciding the matter of internal reservation for various sections of
people and how the Hon’ble Supreme Court of India has failed to appreciate very
important constitutional philosophy of social justice will be discussed in
detail.
Keywords: Constitution, Economically Weaker Sections,
Reservation, Supreme Court of India, and Social Justice.
Introduction
The issue of grant of reservation has
been the contentious one in India. The very purpose of reservation is to uplift
the poor and downtrodden as they are not adequately represented both in
education and employment. As per as India is concerned, it is very strong in
cultural identity and diverse in many aspects. The reservation for Scheduled
Castes and Scheduled Tribes has been given the Constitutional sanction and
later it has been extended to socially and educationally backward classes
people as it is necessary to uplift them to ensure the representation in all
corner. The very purpose of giving reservation is to assure the concept of
social justice in India. Later, the theme of reservations has been extended to
people belongs to economically weaker sections in India. Before discussing the
reservation of economically weaker sections, it is worthwhile to note the
origin behind the reservation in India.
Historical Background of Reservation
in India
The very foundation of reservation
for the needy is to ensure the social justice but while looking back the
history of introduction of reservation based on the caste is not exempted from
judicial intervention. The very first case for deciding the merit of the
reservation based on caste was discussed in
Srimathi Champakam Dorairajan v. The State of Madras[1].
In that case, State Government of Madras reserved the seats for certain
communities both for State medical and engineering colleges based on the
religion, race, caste etc., but it was questioned based on Article 15 of the
Constitution of India[2]. The
State Government of Madras contented that the said order was passed in
accordance with Art.46 of the Constitution of India[3].
The Court held that Directive Principles of State Policy could not override the
fundamental rights. In result of which, Article.15 of the Constitution of India
was amended by the Constitution (First Amendment) Act,1951 to nullify the
judgement of Supreme Court and inserted a Clause (4) in the Art.15[4]. Again
the question of providing reservation by government of Mysore was questioned in
M.R.Balaji and Ors v. State of Mysore[5].
In that case, the State Government of Mysore passed an order on 26th
July 1958 to place all the communities except the Brahmin community, in the
category of educationally and socially backward classes, Scheduled Castes and
Scheduled Tribes and reserved 75% of the total seats in educational
institutions for these communities. All the above order was supplanted relating
to the reservation of seats and classified the backward classes into two
categories such as backward classes and more backward classes and reserved 68%
of the seats for the same while leaving 32% of the seats for the merit. It was challenged by 23 petitioners before
the Supreme Court of India by way of Writ petition under Art.32 of the
Constitution of India. It is also noteworthy to mention the argument of the
petitioner was that before passing any order under Art.15(4) of the
Constitution of India, the State is required to appoint a commission as
provided under Art.340 which has to give the report for the same. The report
will be placed before the president, then laid before both the Houses of
Parliament along with the memorandum and further stated that even for the
argument sake, if the State can make special provisions under Art.15(4), that
should be made by legislation and not by an executive order but the Supreme
Court held that appointment of commission is not a prerequisite to take any
action under Article 15(4) and it is not necessary that only president can pass
an order. Even if there is any recommendation from either Union or any State,
it is discretion of the both governments to decide and not the president.
Further court held that Art.15(4) says about ‘classes’ and not ‘castes’ and
other factors also should be taken into consideration and it has to be both social
as well as educational and made it clear that reservation must not exceed 50%
in any case[6]. The
Court also was justified the order of government making a classification of
socially and educationally backward classes based on economic condition was
justified[7].
Moreover, in another occasion Supreme Court held that the power of reservation
conferred on the State under Article 16(4) can be exercised in a reasonable
manner not only in appointment but also reservation of selection of posts[8].
The importance of giving reservation of seats for backward classes was
justified by the court and considered as Constitutionally valid[9].
In another case[10], Kerala
High Court held that classification of socially and educationally backward
classes based on caste, religion or community was not consistent with Article
15(4) of the Constitution of India but in contrary Supreme Court of India justified the
reservation of seats made on caste wise[11]. The
state may reserve any post or appointment in favour of any backward class of
citizens who, in the opinion of the State, are not adequately represented in
the services under that State.[12]
This is to provide socio-economic equality to the disadvantaged.[13] The expression “backward class of citizens”
contained in Art. 16(4) would take Scheduled Castes and Scheduled Tribes within
its purview.[14]
The second Backward Classes
Commissioner, Mr.B.P. Mandal, submitted his report in 1980. In August 1990, the
Government declared reservation of 27% seats in government service based on
this report.[15] This
was challenged an unconstitutional. A nine-Judge Bench has decided this case in
November,1992, rejecting that challenge.[16] It is also important to note here that the
Court has not itself enumerated the ‘backward classes’ but has directed the
Government to set up a commission to specify the backward classes, in the light
of the principles laid down by the Court. In result of which, Parliament has
already enacted the National Commission for Backward Classes Act,1993 for this
purpose and also in August, 1993, a 5-member Commission has been constituted
under the Chairmanship of Justice R.N.Prasad. Parliament has the right to make or unmake any
law whatever[17]. Contrary to many countries newly independent
after World War II, which were born authoritarian or soon became so, Indian
democracy flourished in its first twenty years, its roots from the
pre-independence, nationalist movement growing ever stronger. This was so even
while Nehru and others occasionally showed ambivalence about the effectiveness
of a democratic constitution for fostering social revolution and preserving
national integrity[18]. Reservation does not rule out the merits.
Judging of merit may be at several tiers. It may undergo several filtrations[19]. It
further stated by nine-judge bench that there can be no reservation solely
based on economic criteria as the constitution of India did not provide the
same. The condition precedent for the
exercise of the power conferred by Article 16(4) is that the States ought to be
satisfied that any backward class of citizens is not adequately represented in
its services. This condition precedent may refer either to the numerical
inadequacy of representation in the services or even to the qualitative
inadequacy of representation.[20] The advancement of backward classes requires
not only that they should have adequate representation in the lowest rung of
services but they should aspire to secure adequate representation in selection
posts in services as well[21]. N.M.Thomas
case ruled that Article 16(4)[22]
allows the state to provide for reservation, is not an exception to equality
but rather a facet of Article.16(1) and held that some caste classification
like those inherent in reservation are indeed reasonable. Indra Sawhney 1992- it was noted that
reservation should not exceed 50 per cent and reminded the quotation of
Dr.B.R.Ambedkar that reservation shall be confined to a minority of seats and
excessive reservation would breach the principle of equality of opportunity. It
is also pertinent to mention here that economic backwardness was the only
criterion that can be devised to determine social and educational backwardness[23].
Judicial Analysis of Reservation in India
In M. Nagaraj v. Union of India[24] the Supreme Court of
India validated the parliament decision[25] to
extend the reservations for SC/STs to include promotions (reservation in
promotion) but it was very difficult for the central and state governments to
grant such reservations. There are three conditions imposed by the Supreme
Court while delivering the judgement such as follows[26]: 1.
State must show the backwardness of the class 2. It must also show that the
class is inadequately represented in the position or service 3. It must show
that the reservations are in the interest of administrative efficiency. The moot question is that whether there is a
fundamental right to reservation[27].
In Mukesh
Kumar v. State of Uttarakhand case
the issue was that promotion of the reservation in public services of SCs or
STs for the post of Assistant Civil Engineer in public service, Department,
Government of Uttrakhand. In this case the High Court of Uttarakhand directed
the state government to gather quantitative data regarding the deficiency of
the representation of SCs or STs candidates in government services and further
said that this data would empower the State Government to examine and take
decisions on the matter related to reservation. The Hon’ble Supreme Court has
stated that the authorities of the State Government are not required to promote
public appointments or positions to the individuals belonging to the SCs or STs
and to generate a reservation for that purpose. It is also worthwhile to note
here that the court held that promotion of reservation does not fall under the
ambit of the fundamental rights which can be maintained and hence no writ
petition of mandamus can be issued for this purpose and no fundamental right
has been provided for an individual to move forward to claim reservation in
promotions and the constitution.
In Jarnail Singh v. Lacchmi Narain Gupta[28]
there was an issue of correctness of the decision of M.Nagaraj case relating
to equality of opportunity in the matter of public employment and placed the
argument that the concept of creamy layer has not been applied in Indra Sawhney
case but it was applied for SC’s and ST’s. There are three issues raised in
this case such as 1. Whether the Nagaraj judgement should be reconsidered; 2.
Is it mandatory to collect the quantifiable data to prove the backwardness for
promotion and 3. Whether the creamy layer among the scheduled castes and the
scheduled tribes should be barred for obtaining promotion by way of
reservation. The Supreme Court said that Nagaraj case does not need to be
referred to a seven-judge bench and stated that the provision for mandating the
State to collect quantifiable data to prove the backwardness of the Scheduled
Castes and the Scheduled Tribes is totally contrary to Indra Sawhney case and
making this provision is invalid and confirmed the application of creamy layer
to promotions for Scheduled castes and Scheduled Tribes[29]. There is
a mechanism which helps the State to decide the parameter for fixing the
reservation and include in Ninth Schedule of the Constitution[30].
Contemporary Issues of Reservation
for Economically Weaker Sections in India
The reservation for economically
weaker sections has been contentious one from the day of adoption in the
Constitution of India but root cause for this reservation has many
constitutional amendments[31].
Art.342A[32] of the
Constitution of India has been focused on reservation for economically weaker
sections[33]. In
addition to this, 105th Constitutional Amendment was brought
regarding socially and educationally backward classes[34]. In Dr.Jaishree Laxmanrao Patil v. The Chief
Minister and Others[35] Constitution
Bench of the Supreme Court of India had strike down the Maratha quota in excess
of 50% ceiling limits as unconstitutional. Furthermore, the court said that
“Neither the Gaikwad Commission nor the High Court have made out any situation
for exceeding the ceiling of 50 % reservation for Marathas. Therefore, there
are no extraordinary circumstances for exceeding the ceiling.” The basic reason
for struck down the Maharashtra Socially Educationally Backward Classes
Act,2018 was that no extraordinary circumstances were made out to grant
separate reservation for Maratha community and if granted it will violate basic
principle of equality as enshrined in Art.16 of the Constitution of India[36]
because Maharashtra SEBC Act,2018 provided 16% reservation for Marathas in jobs
and education which resulted in reservation in Maharashatra exceeded to 68%. While
granting reservation for Maratha Community by way of enacting the legislation
namely the Maharashatra State Reservation (of seats for admission in educational
institutions in the State and for appointments in the public services and posts
under the State) for Socially and Educationally Backward Classes(SEBC) Act,2018
, the Bombay High Court[37]
upheld the validity of reservation but held that 16% reservation is not
justifiable and altered as reservation should not exceed 12% in employment and 13% in education as
recommended by Backward Commission. The Court further held that ceiling of
reservation can be exceeded under exceptional and extraordinary circumstances
and observed that Maratha reservation was based on justifiable data submitted
by the Backward Commission[38].
There is an interpretation of the Constitutional Amendments (102,103 and 105)
by the Supreme Court of India which is not beyond the criticism[39]. In
Vikas Balwant Alase & Ors v. Union of India through Secretary & Ors[40] held
that Maharashtra Government’s decision
to allow members of the Maratha community to avail benefits under the Economically
Weaker Section category midway through an electricity distribution recruitment
drive as Maratha community candidates were aware that their selection process
would be subject to Supreme Court order in the Maratha Reservation matter. There
is a concrete policy in India to give the reservation to socially and educationally backward classes and Scheduled Castes and
Scheduled Tribes. It is also matter of debate by way of introducing the 103rd
Constitutional amendment introduced in Article 15(6)[41]
of the which give the power to state to make special provisions for any
economically weaker sections of citizens other than those mentioned in
educationally backward classes and Scheduled Castes and Scheduled Tribes. In
addition to this, Article 16(6) also have been introduced to enable reservation
for economically weaker sections other than the socially and educationally
backward classes and Scheduled classes and Scheduled Tribes in public
employment and education[42]. It is a matter
of debate about reservation even 70 years after adoption of the
Constitution. The recent 103rd
Amendment in the Constitution of India has created the issues for reconsidering
the reservation as it is providing the reservation for economically weaker
sections and it retains a caste dimension by limiting economically weaker
section to the upper caste but excluding lower castes and scheduled tribes. Dr
B.R.Ambedkar said that caste system is not just a division of labour but a
division of labourers. In Janhit
Abhiyan v. Union of India[43], the
Constitutional validity of 103 Amendment Act,2019 was challenged it citing the
reason that it was unconstitutional and a breach of the basic structure
doctrine and because of this amendment the State became empowered to make a
special provision regarding reservation for the economically weaker section
with an upper limit of 10% by virtue of addition of Articles 15(6) and 16(6) in
the Constitution of India[44].
The important provision in the amendment was that state has empowered to give a
ten percent reservation to economically weaker sections of the society in the
educational institutions and employment opportunities excluding of Scheduled
Castes, Scheduled Tribes and non-creamy layer Other Backward Class and it is
merely enabling in nature rather than mandatory, i.e., it does not mandate the
institutions to provide the 10% ceiling reservation to the Economically Weaker
Sections classes but enable the state to make arrangements for the same. It is
also important to note here about issued raised as follows; 1. Economic
criteria cannot be the sole determinant in allowing reservation for a
particular section of society and thus it infringes the basic structure of the
constitution 2. The defined 10% upper limit of reservation for the economically
weaker sections directly breaches the 50% cap of reservation and directly goes
against the ethos and jurisprudence of reservation and violates the equality
principles resulted in breach of basic structure of the Constitution of India
and exclusion of socially and
educationally backward classes i.e., SCs, STs, and OBCs from these special
provision for economically weaker sections is inexplicably discriminatory in
nature and thus violates the basic structure of the constitution.
Conclusion and Suggestions
The internal reservation for
economically weaker sections has been a matter of debate from date one in which
it was granted. The one section of people has welcomed the steps taken by the
State. Another section of people has raised the issues that without making any
demand by the people in the fullest extents, it has been done it in a speedy
manner without any quantifiable data citing the reason that it will be useful
for them. Even though there is a Constitutional guarantee for economically
weaker sections to enjoy the 10 % reservation, it has created huge uproar. The
Supreme Court of India has backed the decision of the State and validated the
same. Being the guardian of the Constitution of India, the Supreme Court of
India should have been acted to ensure the social justice but here what is
happened to the majority in the name of reservation is injustice. Nobody will
object the reservation for economically weaker sections but it should have been
done in a proper manner by way of appointing the commission to analyse the pros
and cons and collect the quantifiable data, then to take a decision to provide
the numerical value for grant of reservation. The Supreme Court of India also
has missed the opportunity to analyse it in wider perspectives keeping the
social justice in mind. Therefore, it is the right time that State should take
an initiative for caste census and fix the percentage of reservation based on
population of each caste without affecting other. Otherwise, it would be like
futile exercise to speak about reservation and social justice.
* Associate Professor (Senior), VIT
School of Law, Vellore Institute of Technology, Chennai-600 127.
[1] Srimathi Champakam Dorairajan v. The State of
Madras AIR 1951 SC 226.
[2] Art.15. Prohibition of
discrimination on grounds of religion, race, caste, sex, or place of birth.
[3] Art.46.Promotion of educational
and economic interests of Scheduled Castes, Scheduled Tribes, and other weaker
sections.
[4] Art.15(4) of the Constitution of
India states that Nothing in this article or in clause (2) of article 29 shall
prevent the State from making any special provision for the advancement of any
socially and educationally backward classes of citizens or for the Scheduled
Castes and the Scheduled Tribes.
[7] Chitralekha v. State of Mysore,
AIR 1964 SC 1823.
[8] General Manager, S.Rly v.
Rangachari, AIR 1962 SC 36.
[9] Venkataraman v. State of Madras,
AIR 1951 SC 229.
[10] Jacob Mathew v. State of Kerala,
AIR 1964 Kerala 39.
[11] P. Rajendran v. State of Madras,
AIR 1968 SC 1012; Periakaruppan v. State of Tamil Nadu, AIR 1971 SC 2303.
[12] The Constitution of India, art.16(4).
[13] State of U.P v. Dr. Dina Nath
Shukla, AIR 1997 SC 1095.
[14] E.V.Chinnaiah v. State of A.P.,
(2005) 1 SCC 394.
[15] Dr. Durga Das Basu, Introduction
to the Constitution of India 423(Lexis Nexis, Haryana, 21st
edn., 2013).
[16] Indra Sawhney v. Union of India,
(1992) Supp. (3) SCC 217.
[17] A.V. Dicey, An Introduction to
the Study of the Law of the Constitution 34 (Universal Law Publishing Co,
New Delhi,6th edn., 2012).
[18] Granville Austin, Working A
Democratic Constitution A History of the Indian Experience 388(Oxford
University Press, New Delhi,17th impression,2020).
[19] M P Jain, Indian Constitutional
Law 986 (Lexis Nexis, Haryana, 7th edn.,2014).
[20] Southern Railway v. Rangachari,
AIR 1962 SC 36.
[21] Mahendra Pal Singh, V.N.
Shukla’s Constitution of India 118 (Eastern Book Company, Lucknow,12th
edn., 2013).
[22] Art.16(4) of the Constitution of
India; “Nothing in this article shall prevent the State from making any
provision for the reservation of appointments or posts in favour of any backward
class of citizens which, in the opinion of the State, is not adequately
represented in the services under the State.”
[24] M.Nagaraj v. Union of India AIR 2007 SC 71.
[25] The Constitution (Seventy Seventh
Amendment) Act,1995 which inserted Article 16(4A); The
Constitution (Eighty First Amendment) Act,2000 which added Article 16(4B); The Constitution (Eighty Second Amendment) Act,2000 which
added Article 335 and The Constitution (Eighty Fifth Amendment) Act,2000
which added “consequential seniority” for SC/STs under 16(4B).
[26] Available at: https://www.scobserver.in/cases/jarnail-singh-v-lacchmi-narain-gupta-reservation-in-promotion-case-background/(last visited
on 15.05.2023).
[27] Mukesh
Kumar v. State of Uttarakhand (2020) 3 SCC 1 : the court said that
there is no fundamental right to reservation.
[28] Jarnail Singh v. Lacchmi Narain Gupta, Civil Appeal No. 629 of 2022 (Arising out of SLP (C) No. 30621 of 2011), Judgement delivered on 28th January,2022.
[29] Available at:
https://blog.ipleaders.in/jarnail-singh-vs-lachhmi-narain-gupta-case-study(last
visited on 19.06.2023).
[30] IR Coelho v. State of Tamil
Nadu AIR 2007 SC 861- The Court held that if any law found inconsistent
with Part 3 of the Constitution even included in Ninth Schedule of the
Constitution would be struck down by the process of judicial review and
reiterated that judicial review is the part of the basic struct doctrine.
[31] The
Constitution (One Hundred and Second Amendment) Act,2018 resulted in
constitutional status to the National Commission for Backward Classes. Moreover,
it has taken away the power of the State Governments to identify socially and
educationally backward classes (SEBC) and power to identify the SEBC lies with
the Centre but make suggestions to the President or the statutory commissions
for inclusion, exclusion, or modification in the SEBC list.
[32] Art.342A inserted by the
Constitution (One Hundred and Second Amendment) Act,2018, s.4(w.e.f.15-8-2018).
[33] Art.342A of the Constitution of
India- Socially and educationally backward classes and mentioned that the
president may with respect to any State or union territory and where it is a
State after consultation with the Governor, thereof, by public notification
specify the socially and educationally backward classes in the Central List
which shall for the purpose of the Central Government be deemed to be socially
and educationally backward classes in relation to that State or Union territory
as case may be.
[34] The Constitution (One Hundred and
Fifth Amendment) Act,2021 was brought to amend Articles 338 B, 342A and 366 and
to restore the power of the state governments to identify Other Backward
Classes that are socially and educationally backward and to nullify judgement
of the Supreme Court namely Dr. Jaishree Laxmanrao Patil v. The Chief
Minister and Others Civil Appeal No.3123 of 2020 Supreme Court, which had
empowered only the Central Government for such identification.
[36] Art.16 of the Constitution of
India mentioned about Equality of opportunity in matters of public employment.
[37] Dr. Jaishree Laxmanrao Patil v. The
Chief Minister and Others,
Public Interest Litigation No.175 of 2018, Bombay High Court.
[38]Available at:https://www.livelaw.in/top-stories/maratha-reservation-bombay-hc-145929(last
visited on 25.06.2023).
[39]Pattali Makkal Katchi v. A.
Mayilerumperumal & Ors
2022 LiveLaw (SC) 333. In this case Supreme Court of India held that internal
reservation of 10.5% to the Vanniyar Community under the Category Most Backward
Classes is unconstitutional and the Constitutional 105th Amendment
Act is prospective in nature and rejected the contention that the Constitution
105th Amendment is clarificatory in nature and should be given
retrospective effect from the date on which 102nd Amendment Act came
into effect because the opponent had questioned the validity of the Tamil Nadu
Special Reservation of seats in Educational Institutions including Private
Educational Institutions and of appointments or posts in the services under the
State with the Reservation for the Most Backward Classes and Denotified Communities Act,2021. It is also stated that
sub-classification amongst backward classes is permissible and State has the
legislative competence to enact the legislation. In V.V.Saminathan v. The
Government of Tamil Nadu W.P.No.15679 of 2021 Madras High Court delivered
judgment on -01.11-2021held that no such commission report was received by the
State Government except a letter in the form of remarks, dated 23.02.2021 from
the Chairman of the Tamil Nadu Backward Classes Commission and there is no data
much less quantifiable data available with the State Government before the
introduction of the impugned Act and
finally held that caste alone cannot be a criteria to make reservation and the
State Legislature has no power to enact such legislation and accordingly, the
State Legislature has no competency to pass the impugned Act. Based on the
above it can be said that Unfortunately 10.5% internal reservation for Vanniyar
in MBC was set aside citing the reason that it was not supported by any data
even though internal reservation for other caste has been given without any
quantifiable data. It resulted in pushing down 100 years back of that vanniyar
community which is against the social justice.
[40] Vikas Balwant Alase & Ors v. Union
of India through Secretary & Ors W.P.
No 2663 of 2021Bom HC.
[41] Art.15(6) of the Constitution of
India says that any special provision for the advancement of any economically weaker sections of citizens other than the
classes mentioned in clauses(4) and (5); and special provisions relate to their
admission to educational institutions including private educational
institutions, whether aided or unaided by a State other than the minority
educational institutions and in case of reservation would be in addition to the
existing reservations and subject to a maximum of ten per cent of the total
seats in each category. It was inserted by the Constitution
(One Hundred and Third Amendment) Act,2019, s.2(w.e.f.14-1-2019).
[42] Art.16(6) of the Constitution of
India says that State has a power to make any provision for the reservation of
appointment or posts in favour of any economically weaker sections of citizens
other than the classes mentioned in clause (4) of art.16, in addition to the
existing reservation and subject to a maximum of ten per cent of the post in
each category. It was inserted by the Constitution (One Hundred and Third
Amendment) Act,2019, s.3 (w.e.f.14-1-2019).
[43] Writ Petition (Civil) No.55 of
2019 Supreme Court of India.
[44] Available at: https://lawbhoomi.com/janhit-abhiyan-vs-union-of-india-2022-case-comment(last visited on 12.07.2023).
Article Information
INTERNAL RESERVATION FOR ECONOMICALLY WEAKER SECTIONS: IS SUPREME COURT OF INDIA DONE INJUSTICE TO SOCIAL JUSTICE
Authors: Dr.P.R.L.Rajavenkatesan
- Journal IJLRA
- ISSN 2582-6433
- Published 2023/08/03
- Issue 7
About Journal
International Journal for Legal Research and Analysis
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