Madhya Pradesh HC Strikes Down 27% OBC Quota, State Moves Apex Court

The Madhya Pradesh High Court struck down a 2019 state statute that increased reservation for Other Backward Classes from 14 percent to 27 percent, declaring the enactment unconstitutional. A division bench comprising Justices Anand Pathak and Vinay Saraf in Jabalpur held that the state government failed to establish extraordinary circumstances justifying a breach of the 50 percent reservation ceiling.

On October 13, 2014, the Madhya Pradesh High Court in Manish Mishra v. State of M.P. quashed an earlier June 30, 2003 state resolution that had similarly sought to increase OBC reservation to 27 per cent.

Constitutional Ceilings and Judicial Scrutiny

In its comprehensive 159-page ruling, the High Court emphasized that statutory quotas must adhere to the 50 percent constitutional ceiling established by the Supreme Court. Citing landmark precedents in the Indra Sawhney and Jaishri Laxmanrao Patil cases, the bench observed that no emergent conditions existed to validate exceeding established reservation caps. The judges affirmed that Other Backward Classes are entitled to affirmative action to the extent of 14 percent in public services and higher educational institutions.

Representation Metrics and Open Competition Success

Evaluating empirical demographic data across higher education and public employment, the court concluded that backward classes are adequately represented under Article 16(4) of the Constitution. The High Court highlighted official datasets demonstrating that backward class candidates are securing approximately 50 percent of open competition seats in the state. Across Madhya Pradesh, a total of 60 percent of seats are allocated across reserved categories, leaving 40 percent under general unreserved competition. Statistical findings indicate that candidates from backward classes secure their 14 percent quota alongside an additional 20 percent through unreserved merit ranking.

To defend the quota, the State submitted a 2023 survey covering roughly 10,000 people, which the High Court rejected.

Directive on Withheld Posts and 87-13 Recruitment Formula

To manage ongoing litigation, the state administration had adopted an 87-13 recruitment formula in September 2022 that kept 13 percent of vacancies on hold. The High Court directed state recruitment agencies to fill the withheld 13 percent posts with unreserved candidates within three months based on existing merit rosters. Significantly, the bench ruled that public appointments finalized under the 27 percent reservation quota between March 2019 and September 2022 will remain protected.

State Appeal to Supreme Court and Political Commitment

Yadav stated that reservation for backward classes remains a priority of utmost importance, affirming government commitment to protecting community welfare. Chief Minister Mohan Yadav directed state legal teams to conduct a rigorous point-by-point examination of the High Court's October 9 judgment to build a robust appellate case.