In a significant judgment delivered by the Supreme Court of India, a batch of appeals was decided in favor of the appellants, who were employees of various nationalized banks and government undertakings. The appeals were led by K. Nirmala & Ors. versus Canara Bank & Anr., with Civil Appeal Nos. 13484-13488 of 2019 forming the lead matter. The other connected appeals included cases involving the Oriental Insurance Co. Ltd. and Hindustan Aeronautics Ltd. The key legal issue was whether employees who joined services based on caste certificates, identifying them as Scheduled Castes (SC) or Scheduled Tribes (ST) in Karnataka, could retain their positions after their caste had been de-scheduled due to changes in state notifications.
Legal Issues Involved:
The crux of the legal battle revolved around the validity of caste certificates issued to individuals based on the Karnataka government’s notifications, which later were deemed invalid after certain communities were de-scheduled from the SC/ST lists. The appellants, who belonged to communities like Kotegara and Kuruba, had their caste certificates cancelled following a 2001 Supreme Court ruling in the case of State of Maharashtra v. Milind, which asserted that only the Parliament has the authority to amend or modify the SC/ST lists under Articles 341 and 342 of the Constitution of India. This decision rendered state government-issued notifications ineffective, leading to the cancellation of the appellants’ caste certificates and subsequent notices of termination from their employers.
Court’s Decision:
The judgment was delivered by a bench comprising Justice Hima Kohli and Justice Sandeep Mehta, who granted leave and collectively addressed the appeals. The Supreme Court overturned the decisions of the Karnataka High Court, which had previously dismissed the appellants’ writ petitions and intra-court appeals.
The Supreme Court observed:
“There cannot be any two views on the proposition that with the issuance of the Government of Karnataka’s circulars dated 11th March, 2002 and 29th March, 2003, the Scheduled Caste Certificates held by the appellants herein stood automatically revoked and they were brought under the unreserved category.”
The Court underscored that the appellants obtained their caste certificates lawfully, without misrepresentation or fraud, and thus could not be penalized by the cancellation of their certificates due to a procedural error by the state. The government circulars dated 11th March 2002 and 29th March 2003 issued by the Karnataka government played a crucial role in protecting the jobs of those affected, reclassifying them under the general merit category while denying them future SC/ST-specific benefits. The Supreme Court upheld this protective measure, noting:
“The circular dated 29th March, 2003 issued by the Government of Karnataka specifically extended protection to various castes, including those which were excluded in the earlier Government circular dated 11th March, 2002.”
Key Observations:
The Supreme Court made several notable observations in its judgment, including the emphasis on the sanctity of employment secured under lawful caste certificates. It criticized the misapplication of the caste de-scheduling process and noted the potential social and professional harm to individuals who had relied on these state-issued certificates in good faith.
The appellants, represented by Arguing Counsels
K.V.Dhananjay and A.Velan,pleaded for the preservation of their employment status under the general category, while respondents, including Canara Bank and other entities, were represented by legal teams that argued for the annulment of jobs secured via invalidated caste certificates. The Supreme Court’s decision thus marks a critical point in caste-related employment law, affirming that procedural safeguards and legislative clarity are paramount in protecting individual rights and careers.
