Context:

The Supreme Court of India’s recent verdicts on reservation, delivered within weeks of each other have provided long-awaited clarity on a contentious issue in public employment who is entitled to compete for General (unreserved) category seats, and under what conditions. These judgments are especially significant for aspirants of Union Public Service Commission (UPSC), State Public Service Commission (PSC), SSC and other competitive examinations, where disputes over cut-offs, relaxations, and category migration have frequently led to litigation and uncertainty.

• • • By addressing two different factual scenarios, the Court has reaffirmed a consistent constitutional principle: merit governs open competition, while reservation remains a targeted corrective mechanism. For General category candidates, these rulings redefine fairness, transparency, and predictability in recruitment processes.

Constitutional and Legal Foundations:

• • • India’s constitutional framework balances formal equality with substantive justice.
      • Article 14 guarantees equality before the law.
      • Article 16(1) ensures equality of opportunity in public employment.
      • Article 16(4) permits reservation for backward classes inadequately represented in services.
      • Article 15(4) allows special provisions for socially and educationally backward classes.
    • The Constitution does not treat reservation as an exception to equality, but as a means to achieve real equality in a deeply stratified society. At the same time, it preserves the idea that unreserved posts must be filled purely on merit, without any category-based advantage. The Supreme Court’s recent rulings reaffirm this dual commitment, social justice without erosion of meritocracy.

Historical Evolution of Reservation Policy:

• • • Roots in Social Reform: Reservation policies predate Independence. Social reformers like Jyotirao Phule and Periyar E.V. Ramasamy highlighted caste-based exclusion from education and state power. In 1902, Chhatrapati Shahu Maharaj of Kolhapur introduced reservations in administration among the earliest affirmative action measures in India. During colonial rule, caste exclusion was addressed through communal representation, culminating in the Communal Award (1932). The subsequent Poona Pact between Mahatma Gandhi and Dr. B.R. Ambedkar ensured reserved representation within a unified electoral framework.
    • Constitutional Vision Post-1950: Dr. B.R. Ambedkar emphasized that reservation was not a permanent entitlement, but a temporary corrective to bring marginalized groups to an equal starting point. Initially, reservations were confined to Scheduled Castes and Scheduled Tribes.
    • Mandal Commission and Judicial Intervention: The Mandal Commission (1979) identified OBCs as socially and educationally backward, leading to 27% reservation in central services in 1990. This expansion intensified debates on merit and fairness, particularly among General category youth. The Supreme Court responded in Indra Sawhney v. Union of India (1992) by laying down critical guardrails:
      • Reservation capped at 50%
      • Introduction of the creamy layer principle
    • Crucially, meritorious reserved candidates selected without concessions should not be counted against reserved quotas
    • This doctrine remains central to current jurisprudence.

New Dimensions: EWS Reservation:

The 103rd Constitutional Amendment (2019) introduced 10% reservation for Economically Weaker Sections (EWS) among those not covered by SC/ST/OBC quotas. This marked a philosophical shift from purely caste-based disadvantage to economic vulnerability, while still preserving open competition for General seats.

About The Two Recent Supreme Court Verdicts:

Rajasthan High Court Recruitment Case (December 19, 2025)

• • • Facts:
      • Recruitment to clerical posts in the Rajasthan judiciary.
      • Cut-off marks for several reserved categories were higher than the General cut-off.
      • Some SC/OBC/EWS candidates scored above the General cut-off but below their own category cut-off.
      • They were excluded from shortlisting solely due to their category.
    • Supreme Court’s Ruling:
      • The General (open) category is not exclusive to unreserved candidates.
      • Any candidate who meets the General cut-off without availing any relaxation must be included in the open list from the very first stage.
      • The Court rejected the argument that this amounted to “migration” or “double benefit”.
    • Key Principle:
      • Merit-based inclusion in the open category is not a reservation benefit.

Karnataka / IFS Cadre Allocation Case (January 6, 2026):

• • • Facts:
      • An SC candidate cleared the IFS preliminary examination using relaxed cut-off marks.
      • In the final merit list, he ranked higher than a General category candidate.
      • He claimed entitlement to a General (unreserved) insider cadre.
    • Supreme Court’s Ruling:
      • The IFS examination is a single, integrated selection process.
      • Once a candidate avails any relaxation at any stage, they cannot later claim unreserved status.
      • Final merit cannot erase earlier concessions.
    • Key Principle:
      • Relaxation at the entry gate cannot be erased by later performance.

Harmonising the Two Judgments:

• • • Though factually distinct, the verdicts reinforce a coherent constitutional doctrine.
    • Reserved category candidates can be included in the General category if:
      • They meet all General standards
      • They do not avail any relaxation (age, marks, attempts, cut-offs)
      • Their selection is based purely on merit
    • Reserved category candidates CANNOT be included if:
      • They use any concession at any stage
      • Even if they later outperform General candidates
      • This dual framework balances merit-based equality with affirmative justice.

Implications for General Category Aspirants:

• • • Open Category Is Truly Open: General seats are not reserved for the unreserved. They are open to anyone who qualifies purely on merit. This reinforces Articles 14 and 16 by preventing arbitrary exclusion based on social identity.
    • Protection Against “Double Benefit”: A long-standing grievance among General aspirants was that candidates who used relaxations later occupied General seats. The Court has decisively ruled against this practice, ensuring that reservation benefits do not spill over into open competition.
    • Higher Competition, Clearer Rules: Competition for General seats may increase, but only from candidates who genuinely qualify without assistance. The rules are now transparent and predictable.
    • Administrative and Institutional Clarity: Recruiting agencies must:
      • First prepare a merit-only open list
      • Then fill reserved seats
    • Avoid category-wise silos that violate constitutional equality

This reduces post-result litigation and enhances trust in recruitment systems.

Policy and Social Context:

• • • These judgments come amid broader debates on:
      • Creamy layer applicability
      • Internal reservation
      • Reservation caps
      • Efficiency of public administration
    • While these issues extend beyond the current rulings, the Court’s approach reflects judicial restraint, refining boundaries without expanding or diluting reservation.

Conclusion:

The Supreme Court’s latest verdicts do not dismantle reservation, nor do they privilege merit at the cost of social justice. Instead, they clarify the rules of engagement. They reaffirm merit as the governing principle of open competition, reservation as a targeted corrective, not an all-purpose advantage and equality of opportunity, not mechanical equality. The Constitution guarantees fair competition, not insulation from competition. Together, these judgments strengthen the delicate constitutional balance between social justice and meritocracy, which lies at the heart of India’s democratic governance and public service recruitment.