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Supreme Court of India 2021-12-16 allowed

Sadhana Singh Dangi & Others vs Pinki Asati & Others Respondents

Bench: 3 — Lalit, Uday Umesh Lalit, Sanjay Kumar, Alok Aradhe

In Brief

The Supreme Court resolved conflicting High Court interpretations on horizontal reservation in recruitment. The core dispute concerned whether reserved-category candidates (OBCs, SCs, STs) who score higher marks than unreserved (General) candidates can be selected for unreserved posts. The Madhya Pradesh High Court had held that at the horizontal reservation stage, reserved candidates must be adjusted only within their own categories, even if more meritorious than unreserved candidates. The Supreme Court overruled this, approving the opposite view: merit must prevail universally. Reserved-category candidates scoring higher cannot be denied unreserved posts to accommodate less meritorious unreserved candidates. The Court distinguished between placement in merit lists (merit-based) and seat allotment (category-wise), holding that both serve merit simultaneously without sacrificing reservation principles.

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Constitutional Law Civil Service Recruitment Reservation Policy Merit and Selection Equal Opportunity Horizontal Reservation Vertical Reservation Discrimination Law

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