STATE OF UTTAR PRADESH V. DR. DINA NATH SHUKLA AND ANR INSC 98

State Of Uttar Pradesh vs Dr. Dina Nath Shukla & Anr INSC 98 Date: 31st Jan, 1997

Facts: The legislature of Uttar Pradesh enacted the Uttar Pradesh Public Services Act, 1994, which concerns reservations for Scheduled Castes, Tribes, and other Backward Classes. The University of Allahabad issued an advertisement on Jan 30th,1995 inviting applications from all eligible persons of posts of Professors, Readers, and lecturers including posts reserved for Scheduled Castes, Scheduled Tribes, and Other Backward Classes. The government issued a clarification to the Act on April 19th, 1995, stating that for the recruitment of Professors, Readers, and Lecturers, the University or College is treated as a unit and the recruitment would be made applying the rule of reservation in respect of all the posts. This came to be questioned in a writ petition. Issue: Whether the University of Allahabad must be taken as a unit for the purpose of recruitment to the posts of Professors, Readers and Lecturers and the posts be fused as three separate categories for application of the rule of reservation for Scheduled Castes, Scheduled Tribes, and other Backward Classes.

Decision: The Supreme Court upheld the High Court’s decision, ruling that reservations should be implemented subject-wise rather than as three separate categories across disciplines in a university. The Vice-Chancellor of University of Allahabad would work out the details, make fresh advertisements and have the selection done in accordance with law and appointments made accordingly. No costs and the appeal is accordingly disposed of.

Majority Decision Reasoning: Subject-specific reservations ensure transparency, enabling candidates to know which posts are reserved and for whom, while fusing posts across disciplines creates ambiguity and hinders fair competition, and may lead to over-lapping in application to the posts. It would also be difficult for candidates to know which posts are available if the posts are advertised without subjectwise specifications. The Court relied on constitutional provisions such as Articles 14, 15, 16, and 335 to uphold the principles of equality and fairness. The Act mandates that the reservation policy be implemented without compromising administrative efficiency and the merit-based selection process.

Impact of the case: Established that reservations in educational institutions must be applied subject-wise rather than treating the entire University or College as a single unit. Ensured fairness and transparency in reservation policy by avoiding ambiguity regarding reserved posts. Reinforced the principle that reservation policies must align with the constitutional objective of equality and equitable representation.