The Allahabad High Court, Lucknow Bench, has dismissed a Public Interest Litigation (PIL) filed by Satya Narain Shukla and another petitioner, which sought to extend the benefits of state welfare schemes meant exclusively for Scheduled Castes (SCs), Scheduled Tribes (STs), Other Backward Classes (OBCs), and minorities to all below poverty line (BPL) individuals, regardless of caste or community.
Background of the Case
The PIL, numbered 35231 of 2018, was filed by Satya Narain Shukla and another petitioner, both appearing in person. The petitioners argued that the current beneficiary-oriented schemes, which are exclusively for SCs, STs, OBCs, and minorities, should also be extended to economically disadvantaged individuals from all communities. They contended that such an extension would align with the principles of social and economic justice enshrined in the Constitution of India.
Legal Issues Involved
The primary legal issues in this case revolved around:
1. Constitutional Validity: Whether the exclusion of economically disadvantaged individuals from general categories from certain welfare schemes violated their right to equality under Article 14 of the Constitution.
2. Policy Formulation: Whether the court could issue a mandamus directing the government to frame policies extending these benefits based on economic criteria rather than caste or community.
3. Judicial Review: The extent to which the judiciary can intervene in matters of policy that are typically within the domain of the Executive and Legislature.
Court’s Decision
The bench, comprising Justice Rajan Roy and Justice Om Prakash Shukla, delivered the judgment on July 5, 2024. The court observed that the relief sought by the petitioners essentially required a change in policy, which falls within the exclusive domain of the Executive and Legislature. The court noted that:
– The petitioners did not provide specific details or material evidence regarding the existing schemes for SCs, STs, OBCs, and minorities that should be extended to BPL individuals from other communities.
– The Constitution (One Hundred and Third Amendment) Act, 2019, which introduced reservations based on economic criteria, had already addressed some of the concerns raised by the petitioners. This amendment allowed for reservations in higher education and public employment for economically weaker sections (EWS), independent of existing reservations for SCs, STs, and OBCs.
– The Supreme Court, in previous judgments, had consistently held that policy formulation is a function of the Executive and Legislature, and courts should not interfere in such matters unless there is a clear violation of fundamental rights.
The court concluded that the issues raised by the petitioners should be addressed through representations to the appropriate government authorities or through legislative processes. Consequently, the PIL was dismissed with the observation that the petitioners are free to pursue their cause before the Executive or Legislature with relevant data and materials.
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Parties and Representation
– Petitioners: Satya Narain Shukla and another petitioner, appearing in person.
– Respondents: State of Uttar Pradesh, represented by the Chief Secretary and others.
– Counsel for Petitioners: S. N. Shukla and G. N. Pandey, appearing in person.
– Counsel for Respondents: Sudhanshu Chauhan, representing respondents no. 3 and 4; V. P. Nag, Standing Counsel for the State.
