State Borders Block Caste Benefits: MP High Court Denies SC Reservation to Migrant Anganwadi Aspirant

In a ruling that underscores the state-specific nature of reservation policies, the High Court of Madhya Pradesh at Gwalior has held that a Scheduled Caste (SC) certificate issued by one state cannot be used to claim reservation benefits in another state, even if the caste is recognized as SC in both. Justice Anand Singh Bahrawat dismissed Writ Petition No. 7568 of 2018 filed by Smt. Hemlata Arya, directing authorities to reassess her eligibility for an Anganwadi Worker post without SC benefits.

From Rajasthan Roots to MP Dispute: The Anganwadi Appointment Saga

Smt. Hemlata Arya, a resident of Ward No. 8, Baroda, Tahsil Baroda, District Sheopur in Madhya Pradesh, applied for the Anganwadi Worker position as an SC candidate. Her caste certificate, issued on 05.09.2016 by the Sub-Divisional Officer (SDO), Kota, Rajasthan, awarded her 61.5 marks, making her the top scorer.

The Project Officer (Respondent No. 4) initially overlooked her claim, appointing others like Famida Bano and later Smt. Kirti Sharma (Respondent No. 5). Arya challenged these before the Additional Collector, Sheopur, who ruled in her favor on 26.07.2017, leading to her appointment on 29.08.2017. Kirti Sharma appealed to the Additional Commissioner, Chambal Division, Morena, who on 04.01.2018 set aside the order and mandated a fresh merit-based appointment after hearings.

Arya then approached the High Court, seeking to quash the Commissioner's remand order and secure her position.

Petitioner's Plea: 'My Certificate Travels with Me'

Arya's counsel argued that the Collector had validated her Rajasthan-issued SC certificate as valid across India. With superior marks, she deserved the post. They contested the remand, claiming procedural lapses and her unquestioned eligibility.

Respondents countered fiercely: As a Rajasthan domiciliary, Arya couldn't import SC benefits to Madhya Pradesh. Her certificate from Kota held no sway here, aligning with the principle that reservations are home-state confined. Kirti Sharma's advocate emphasized merit without undue category claims.

Supreme Precedents Seal the Deal: No Passport for Caste Status

Justice Bahrawat relied on a robust line of Supreme Court judgments to affirm that SC/ST status is geographically tethered. In Bir Singh v. Delhi Jal Board (2018) 10 SCC 312, the Court clarified that migrants lose category benefits in the new state.

Pivotal was Marri Chandra Shekhar Rao v. Dean, Seth G.S. Medical College (1990) 3 SCC 130, stressing that Articles 341 and 342 limit benefits to the "State or Union Territory" specified. Action Committee v. Union of India (1994) 5 SCC 244 elaborated: social hardships vary by state, so identical caste names don't guarantee portability.

Recent affirmations in Ranjana Kumari v. State of Uttarakhand (2019) 15 SCC 664 and Bhadar Ram v. Jassa Ram (2022) 4 SCC 259 reinforced this. A prior MP HC ruling in Smt. Saini v. State of MP (WP 7745/2014) and Smt. Preeti Gehlod (2025) echoed: post-1950 migrants, especially via marriage, forfeit claims.

The Court noted: "the benefit of reservation can be extended only in the home State." Recognition hinges on local backwardness—social, economic, educational—not caste nomenclature alone.

As echoed in media reports, the bench observed that "a person, who migrates from one State to the other does not carry his caste status to the migrating State, even if the same caste is recognized as SC in both States."

Remand Upheld, Fresh Merit Call Without SC Edge

The writ stood dismissed. Noting the petition's unmaintainability against a mere remand, the Court directed the Project Officer to decide afresh per the 04.01.2018 order—treating Arya as general category, hearing all candidates, and issuing a reasoned order within three months.

Key Observations from the Bench

"It is a settled position of law that the benefit of reservation can be extended only in the home State. As the petitioner’s home State is Rajasthan, the benefit of the Scheduled Castes category cannot be extended to her in the State of Madhya Pradesh."

"From the aforesaid, it is lucid that a person, who migrates from one State to the other does not carry his caste status to the migrating State, even if the same caste is recognized as SC in both States."

"The social, economic and educational backwardness are factors, which are never identical or even similar in two different States."

This decision reinforces rigid state boundaries for reservations, potentially impacting countless migrants in public employment and elections. Anganwadi selections in MP will now prioritize local verifications, ensuring benefits reach those facing genuine local disadvantages.