Medical colleges established under Schedule Caste can't be provided with general quota ceiling. HC misinterpreted it

A fresh Allahabad High Court judgment has once again set aflame controversy regarding reservations in higher education. A single-judge bench, in the case of Sabra Ahmad vs Uttar Pradesh, ruled that the four special medical colleges built in Jalaun, Saharanpur, Kannauj, and Ambedkar Nagar under the Scheduled Caste Special Component Plan cannot offer 70 per cent reservation to Scheduled Castes. A division bench of the court later upheld the ruling.

The matter is now before the Supreme Court, which is to rule whether colleges under the Special Component Plan (SCP) fall within the 50 per cent ceiling quota on reservations.

Meanwhile, the high court directive has jeopardized the future of about 100 students. But it has generated a further controversy as other states, including Karnataka, Andhra Pradesh, Telangana, and Kerala, also possess such similar SC/ST reservation special colleges of more than 50 per cent. 

Therefore, this judgment is more politically significant for the BJP as the party is coming towards its current term in office with Yogi Adityanath. The party had already faced a electoral defeat in the 2024 Lok Sabha elections on charges of cancelling reservation and weakening the Constitution.

We put forth that the Allahabad High Court erred in suspending the reservation policy of these four colleges by using the 50 per cent limit ceiling formulaistically released in the Indra Sawhney judgment. The aforesaid ruling, however, explicitly sanctioned the breach of the limit ceiling for compelling reasons in pursuit of substantive equality. Unless overturned, the Allahabad High Court decision would have significant consequences for SC welfare policy and polity, with other high courts potentially issuing similar orders.    

The source of constitutional dispute

The state government of Uttar Pradesh established four special medical colleges under the SCP for SCs. The SCP was brought into force in 1979 to put into effect Article 46, which lays down that "the State shall promote with special care the educational and economic interests of the weaker sections of the people, and, in particular, of the Scheduled Castes and the Scheduled Tribes, and shall protect them from social injustice and all forms of exploitation."

These colleges receive 70 percent of their finances from SCP, so they must reserve 70 percent in the case of SC students. 

This requirement has been disputed in the Allahabad High Court eight years back, and the matter is still pending before a division bench of the court. But the single-judge bench has struck down government orders issued between 2006 and 2015 although they were not prayed for in the petition. While a case is pending before the larger bench, the smaller bench cannot pass an order as it amounts to judicial impropriety. But it directed the government to implement the Uttar Pradesh Reservation Act of 2006 whereby SC reservation is limited to 21 per cent. On 4 September 2025, the division bench of Justices Rajan Roy and Manjive Shukla ordered that the SC students who were already admitted should be shifted to other medical colleges, rendering numerous students uncertain about their academic fate. The court's fundamental misreading

The misuse by the superior court is to consider these special institutions as general educational institutions subject to general schemes of reservation. This mechanical exercise ignores the very constitutional principle of generalia specialibus non derogant, i.e., 'special provisions take precedence over general ones'. The colleges were not established as general institutions to which reservations were appended; they were established as specialized instruments of constitutional justice under Articles 15 and 46.

By adopting a literal interpretation, the court has rendered the transformative intent of these institutions nugatory. This also contradicts Supreme Court rulings, which have maintained that constitutional interpretation must consider legislative intent and constitutional vision as opposed to textual literalism. The high court applied textual literalism.

Constituent Assembly's transformative vision

Constituent Assembly debates document the abiding intent of provisions for the betterment of Scheduled Castes and Scheduled Tribes. S Nagappa of the Constituent Assembly encapsulated this vision in his proposal that there should be a specialized ministry under the minister from the same community, and the need for tangible plans and schemes, and setting aside 5 per cent of central revenues for such plans and schemes.

S Munniswamy Pillai, another Constituent Assembly member, shared the same vision where he argued that the SC/ST officer should review SC/ST advancement after ten years, and if it is short, then the duration of reservation must be prolonged and not terminated automatically.

This constitutional concept is given concrete shape in Article 46, which mandates that "the State shall promote with special care the educational and economic interests of the weaker sections". KM Munshi, the great father of fundamental rights, emphasized that Article 46 was the token of the Constitution's promise of social revolution—to transform India from a caste-ridden to an egalitarian democracy. He viewed it not as charity but rather as a constitutional obligation to address past injustices by means of affirmative state action.