ValkyaEditorial

Equality & Reservation — 73 Valkya Editorial digests

The equality code — Article 14 and the test against arbitrariness, and the reservation jurisprudence under Articles 15 and 16: the 50% ceiling, creamy layer, EWS, sub-classification, and the interplay of horizontal and vertical reservation.

Supreme CourtSupreme Court of India

Neil Aurelio Nunes v. Union of India (2022): OBC reservation in the NEET All India Quota upheld

The Supreme Court upheld 27% reservation for OBC candidates in the All India Quota seats for undergraduate and postgraduate NEET medical and dental admissions. Rejecting the petitioners' merit-versus-reservation framing, the Court held that reservation is not antithetical to merit but furthers distributive justice, and that an examination rank is not a proxy for merit.

Valkya Editorial··6 min
Supreme CourtSupreme Court of India

Saurav Yadav v. State of Uttar Pradesh (2020): A reserved-category candidate who beats the open cut-off takes the open seat on merit

The Supreme Court held that a candidate from a vertically reserved category (SC/ST/OBC) who scores above the general cut-off must be adjusted against the open seats on merit, not counted against the reserved quota. The rule holds even where the candidate also claims a horizontal reservation such as for women. The open category is open to all on merit.

Valkya Editorial··6 min
High CourtHigh Court of Madras

Arjunan Sampath v. The Chief Electoral Officer (2026): plea to bar non-Hindu/Sikh/Buddhist candidates from SC seats dismissed

The Madras High Court (CJ S.A. Dharmadhikari and G. Arul Murugan J.) dismissed a PIL seeking to restrict candidature in Scheduled-Caste-reserved constituencies to those professing Hinduism, Sikhism or Buddhism. The Court held that Returning Officers already possess summary powers to reject fraudulent nominations, and that any grievance over a false declaration must be raised through an election petition, not a writ that micro-manages an election in motion.

Valkya Editorial··8 min
Supreme CourtSupreme Court of India

Kiran Jyot Maini v. Anish Pramod Patel (2024): the factors for fixing permanent alimony

The Supreme Court restated the broad factors a court must weigh in fixing permanent alimony — status, the wife's reasonable needs, qualifications and employment, independent income, the marital standard of living, sacrifices for the family, litigation costs and the husband's capacity. Dissolving the marriage under Article 142, it fixed a one-time settlement of roughly ₹2 crore, holding that alimony must secure a decent life without being punitive.

Valkya Editorial··6 min
LandmarkSupreme Court of India

Shilpa Sailesh v. Varun Sreenivasan (2023): Article 142 can dissolve a marriage on irretrievable breakdown

A five-judge Constitution Bench held that the Supreme Court may, under Article 142, dissolve a marriage that has irretrievably broken down to do complete justice — even without one spouse's consent and bypassing the family-court reference — and that the six-month cooling-off period under section 13B(2) of the Hindu Marriage Act is waivable in a fit case.

Valkya Editorial··7 min
Supreme CourtSupreme Court of India

Mithu v. State of Punjab (1983): striking down the mandatory death sentence under Section 303

In 1983 a five-judge Constitution Bench struck down Section 303 of the Indian Penal Code, which had made death the only punishment for a life-convict who committed murder. A digest of the facts, the holding that a mandatory, discretion-free death sentence violates Articles 14 and 21, and the judgment's place in India's death-penalty jurisprudence.

Valkya Editorial··8 min
High CourtHigh Court of Chhattisgarh

Dr. Samriddhi Dubey v. State of Chhattisgarh (2025): institution-based PG-medical preference struck down

A Division Bench of the Chhattisgarh High Court struck down Rule 11(a) and Rule 11(b) of the State's 2025 PG-medical admission rules, which had reserved State-quota postgraduate seats for candidates who obtained their MBBS from a Chhattisgarh medical college. The Court held the institution-based preference to be a de-facto reservation, ultra vires and violative of Article 14. A digest of the facts, the holding, and the Supreme Court line it applied.

Valkya Editorial··7 min
Supreme CourtSupreme Court of India

Suresh Kumar Koushal v. Naz Foundation (2013): the Supreme Court restores Section 377

In December 2013 a two-judge Supreme Court Bench set aside the Delhi High Court's Naz Foundation judgment and restored Section 377 IPC in full, re-criminalising consensual same-sex conduct between adults. A digest of the appeal, the Court's reasoning on Articles 14, 15 and 21, and how Koushal was first criticised in Puttaswamy and finally overruled in Navtej.

Valkya Editorial··8 min
LandmarkSupreme Court of India

D.S. Nakara v. Union of India: pension as deferred wage, not bounty

On 17 December 1982, a five-judge Constitution Bench held that pension is a right earned by past service — a deferred wage, not a bounty — and struck down a retirement cut-off date that split a homogeneous class of pensioners as arbitrary under Article 14.

Valkya Editorial··8 min
LandmarkSupreme Court of India

Delhi Transport Corporation v. DTC Mazdoor Congress: striking down hire-and-fire

On 4 September 1990, a Constitution Bench of five judges struck down a 'hire and fire' clause permitting termination of permanent employees without reasons and without hearing — holding that audi alteram partem must be read into State termination powers and that arbitrary, unguided dismissal violates Article 14.

Valkya Editorial··9 min
Supreme CourtSupreme Court of India

ASD v. LCSIBD: career, child welfare and the limits of matrimonial cruelty

On 12 May 2026, a two-judge bench expunged findings of cruelty and desertion against a dentist wife who had relocated from Kargil to Ahmedabad for tertiary medical care and to pursue her practice, holding that 'marriage does not eclipse her individuality' and retaining the divorce decree on the ground of irretrievable breakdown under Article 142.

Valkya Editorial··10 min
Supreme CourtSupreme Court of India

In Re Phalodi Accident v. NHAI: commuter safety as an Article 21 right

On 13 April 2026, a two-judge bench held that the safety of commuters on national highways is an integral facet of the right to life with dignity under Article 21, and issued sweeping directions under Article 142 to NHAI, MoRTH, NHIDCL and State PWDs — including a ban on highway-shoulder parking and 75-day compliance reporting.

Valkya Editorial··10 min
TribunalNational Green Tribunal (Principal Bench, New Delhi)

NGT closes the 'deemed Environmental Clearance' loophole: Renu Bala v. MoEF&CC (Omaxe State, Dwarka)

On 22 April 2026, the NGT Principal Bench held that the EIA Notification 2006 does not contemplate any 'deemed approval' of an Environmental Clearance, and directed the Tree Officer, MoEF&CC and the Delhi Pollution Control Committee to act within eight weeks against a 61-acre Dwarka project that had felled approximately 2,000 trees without clearance.

Valkya Editorial··9 min
Supreme CourtSupreme Court of India

Union of India v. Rohith Nathan: OBC creamy layer cannot be decided on income alone

On 11 March 2026, a two-judge bench held that creamy-layer status under the DoPT 1993 Office Memorandum cannot be determined solely on parental income; the status-based and income-based gates must be applied as distinct, and the DoPT clarificatory letter of 14 October 2004 was held ultra vires the substantive 1993 OM framework.

Valkya Editorial··10 min
Supreme CourtSupreme Court of India

Air India v. Nergesh Meerza: the cabin-crew judgment that struck down pregnancy-termination and gave us the sex-plus rule

On 28 August 1981, a three-judge Bench led by Fazal Ali J. struck down the first-pregnancy termination clause and the Managing Director's uncontrolled retirement-extension discretion in the Air India and Indian Airlines service regulations, while upholding the differential retirement age and four-year marriage-bar for female cabin crew on cadre-classification reasoning. A digest of the mixed ruling, the sex-plus doctrine it installed, the feminist critique that followed, and the modern anti-stereotype frame in Anuj Garg, Babita Puniya and Joseph Shine that has substantially overtaken its weaker holdings.

Valkya Editorial··14 min
LandmarkSupreme Court of India

Ashoka Kumar Thakur v. Union of India: the Constitution Bench on 27% OBC reservation in central higher education, the 93rd Amendment and the creamy-layer extension

On 10 April 2008, a five-judge Constitution Bench upheld the Central Educational Institutions (Reservation in Admission) Act 2006 — providing 27% OBC reservation in centrally-funded higher education institutions including the IITs, IIMs, AIIMS and central universities — together with the 93rd Constitutional Amendment that inserted Article 15(5). The Bench extended the Indra Sawhney creamy-layer doctrine to OBC reservation in higher education, preserved the 50% reservation ceiling and required periodic review and quantifiable data. The validity of Article 15(5) for private unaided institutions was left for Pramati (2014) to settle.

Valkya Editorial··15 min
Supreme CourtSupreme Court of India

Indian Federation of App-Based Transport Workers v. Union of India: the gig worker petition

On 13 December 2021, a two-judge bench of the Supreme Court issued notice on a writ petition seeking recognition of gig workers as workers within the Indian labour-law architecture, social security entitlements under the Code on Social Security 2020 Chapter IX, and operational implementation of the Unorganised Workers' Social Security Act 2008 — a doctrinal classification question that remains pending.

Valkya Editorial··11 min
High CourtHigh Court of Bombay

Kunal Kamra v. Union of India: the Fact Check Unit and the 2-1 split

A Bombay High Court division bench split 1-1 in January 2024 on the constitutional validity of the IT Rules 2023 Fact Check Unit. The tie-breaking opinion of Justice A.S. Chandurkar in September 2024 struck down Rule 3(1)(b)(v) — vague, overbroad, and structurally inviting the state to be judge in its own cause.

Valkya Editorial··10 min
Supreme CourtSupreme Court of India

Lucknow Public School v. State of Uttar Pradesh: the Supreme Court hardens the s.12(1)(c) RTE allotment duty and re-frames the 25% reservation as a 'national mission'

On 28 April 2026 the Supreme Court — Justices P.S. Narasimha and Alok Aradhe — dismissed the appeal of Lucknow Public School, Eldico, which had refused admission to a child from a disadvantaged group duly allotted by the State Government under Section 12(1)(c) of the RTE Act and the UP RTE Rules 2011 for the 2024-25 pre-primary year on the school's plea of 'uncertainty' about eligibility. The ruling holds that once a State authority allots a child under the RTE scheme, the neighbourhood school's duty to admit is mandatory and immediate; the school cannot interpose its own eligibility scrutiny or procedural conditions; and any refusal or delay is unlawful. The Bench characterised the 25% RTE reservation as a 'national mission' rooted in Article 21A, hardening the operational architecture that Society for Unaided Private Schools v. Union of India (2012) had set in motion.

Valkya Editorial··14 min
Supreme CourtSupreme Court of India

Pradeep Jain v. Union of India: how the Supreme Court read 'one nation, one domicile' into Article 14 and dismantled state-domicile reservation in medical admissions

On 22 June 1984, a three-judge bench of Justice P.N. Bhagwati, Justice A.N. Sen and Justice Ranganath Misra held that wholesale state-domicile reservation in MBBS admissions is unconstitutional under Article 14 — every Indian citizen has only one domicile, the territory of India under Article 5. Institutional preference for graduates of the same institution was preserved as qualitatively distinct from domicile reservation; PG specialty admissions were directed to be on all-India merit. Saurabh Chaudri (2003) raised the all-India PG quota to 50% and Dr Tanvi Behl (2025) reaffirmed the framework against Chandigarh's UT-resident quota.

Valkya Editorial··14 min
Supreme CourtSupreme Court of India

Pramati Educational Trust v. Union of India: the 86th and 93rd Amendments upheld and the two-step minority exemption completed

On 6 May 2014, a five-judge Constitution Bench of the Supreme Court — in a unanimous judgment authored by Justice A.K. Patnaik — upheld both the 86th Constitutional Amendment Act 2002 (inserting Article 21A) and the 93rd Constitutional Amendment Act 2005 (inserting Article 15(5)). The Bench held that the Right of Children to Free and Compulsory Education Act 2009 and the special-provisions power under Article 15(5) do not apply to minority educational institutions, whether aided or unaided. Read with Society for Unaided Private Schools of Rajasthan v. Union of India (2012) — which had already carved out the minority unaided exemption — Pramati completes a two-step minority exemption from the post-Article 21A reservation architecture. A close reading of Patnaik J's reasoning on basic structure, the Article 30(1) minority autonomy core, the relationship with T.M.A. Pai and Inamdar, the legislative reversal of Inamdar's holding on private unaided reservation, and the live September 2025 reference questioning the Pramati exemption.

Valkya Editorial··18 min
Supreme CourtSupreme Court of India

Secretary, Ministry of Defence v. Babita Puniya: Permanent Commission for women officers and the rejection of gender stereotypes

On 17 February 2020, a two-judge Bench of Justices D.Y. Chandrachud and Ajay Rastogi held that the Ministry of Defence policy denying Short Service Commission women officers Permanent Commission in non-combat arms of the Indian Army — Army Service Corps, Ordnance Corps, EME, Signals, Intelligence Corps, AEC, JAG and the other streams in which women had been inducted as SSC officers — violates Articles 14, 15 and 16. The Court rejected the Centre's submissions about 'physiological limitations', 'domestic obligations' and unit cohesion as constitutionally impermissible gender stereotypes, set aside the 'staff appointments only' restriction in the 25 February 2019 policy letter, and directed that all serving SSC women officers be considered for Permanent Commission on terms equivalent to male officers with consequential entitlements. *Babita Puniya* installed the anti-stereotype framework that *Annie Nagaraja* (Navy) and *Lt Col Nitisha* (indirect discrimination) elaborated, and that *Lt Col Pooja Pal* (2026) operationalised through Article 142 structural compensatory relief.

Valkya Editorial··15 min
Supreme CourtSupreme Court of India

State of Karnataka v. Umadevi (3): the Constitution Bench that closed the door on regularisation-by-mandamus

On 10 April 2006, a five-judge Constitution Bench led by Sabharwal CJ and authored by Balasubramanyan J held that public employment must follow Article 16 — competitive, advertised, merit-based recruitment to sanctioned posts — and that temporary, casual, daily-wage, ad hoc or contractual appointees made outside that scheme acquire no fundamental right to regularisation however long they may have served. The judgment drew a sharp doctrinal line between 'irregular' and 'illegal' appointments, granted a one-time, fixed-date paragraph-53 exception for irregular appointees who had completed ten years of service on sanctioned posts as of 10 April 2006, and overruled *Dharwad PWD*, *Daily Rated Casual Labour v. Union of India* and *Ashwani Kumar v. State of Bihar*. The decision remains the gravitational centre of Indian regularisation jurisprudence two decades on.

Valkya Editorial··16 min
Supreme CourtSupreme Court of India

Subhash Desai and the Maharashtra political crisis: a Constitution Bench redraws the Governor, the Speaker, the whip and the Tenth Schedule

On 11 May 2023 a five-judge Constitution Bench of the Supreme Court unanimously delivered Subhash Desai v. Principal Secretary, Governor of Maharashtra — the apex court's most consequential Tenth Schedule ruling since Kihoto Hollohan. The Court held the Governor's 30 June 2022 floor-test call unjustified, declined to restore the Thackeray Government because of Uddhav Thackeray's voluntary resignation, struck down the Speaker's recognition of a rival whip on the principle that the whip is appointed by the political party and not the legislature party, and referred Nabam Rebia to a seven-judge bench. A close reading of the architecture, the doctrinal lines, and the unfinished business.

Valkya Editorial··17 min
Supreme CourtSupreme Court of India

Subramanian Swamy v. Director, CBI: how the Constitution Bench buried the Single Directive a second time

On 6 May 2014, a five-judge Constitution Bench led by Chief Justice R.M. Lodha struck down Section 6A of the Delhi Special Police Establishment Act 1946 — the statutory revival of the executive 'Single Directive' that this Court had abrogated in Vineet Narain (1998) — as violative of Article 14. The judgment closes the doctrinal arc: an administrative immunity, struck down in 1997-98, cannot be reintroduced in legislative form when the underlying constitutional defect remains. The decision became the analytical scaffold for CBI v. R.R. Kishore (2023) and frames the still-pending challenge to Section 17A of the Prevention of Corruption Act 1988 inserted by the 2018 amendment.

Valkya Editorial··16 min
Supreme CourtSupreme Court of India

Umesh Kumar Nagpal v. State of Haryana: compassionate appointment as a narrow exception, not an heirloom

The Supreme Court's foundational decision on the doctrinal limits of compassionate appointment in public employment. A 2-judge bench held that compassionate appointment is not a constitutional or fundamental right but a narrow exception to the *Article 16* rule, designed to provide immediate financial relief to the family of a deceased employee — not to bestow the deceased's post as an 'heirloom' on his progeny. The judgment installed the junior-most-post discipline, the financial-condition examination, the reasonable-time requirement, and a clear limit on judicial direction outside the rules. Thirty years on, the *Sawant J* framework remains the operative anchor of compassionate-appointment jurisprudence, read together with *Canara Bank v. M. Mahesh Kumar* (2015), *Canara Bank v. Ajithkumar G.K.* (2025), and the post-*Umadevi* (2006) regularisation discipline.

Valkya Editorial··12 min
Supreme CourtSupreme Court of India

Alpha Corp Development v. Greater Noida Industrial Development Authority: the Supreme Court authorises veil-piercing in real-estate CIRP

On 5 May 2026 a two-judge bench of the Supreme Court, in Alpha Corp Development Pvt Ltd v. Greater Noida Industrial Development Authority, authorised the lifting of the corporate veil during the CIRP of a holding company so that the land assets held by its SPV subsidiaries — which had been used by the group to shield real-estate landbanks from homebuyer claims — could be drawn into the resolution estate. Decided on the factual matrix of the Earth Infrastructures group and producing relief for over 4,200 homebuyers, the ruling is the first clear apex pronouncement that the corporate-separateness principle can be lifted in real-estate insolvencies where the multi-SPV structure has been used to defeat the substantive resolution objective. A close reading of the bench's reasoning, the Article 142 architecture, and what the ruling means for SPV-structured developers, homebuyer associations, and the 2026 RERA-IBC recalibration.

Valkya Editorial··14 min
High CourtDelhi High Court

CMYK Printech v. Ideal Multi Media: how the Delhi High Court restrained a Bhopal publisher's use of 'The Pioneer'

On 10 April 2026, Justice Tushar Rao Gedela of the Delhi High Court granted an ex parte ad interim injunction restraining a Bhopal-based publisher from using 'The Pioneer' trademark and from copying the contents of the plaintiff's newspaper. The judgment, in CS(COMM) 338/2026, treats the defendant's conduct — following the revocation of a 2004 Memorandum of Understanding — as a composite trademark-and-copyright infringement under the Trade Marks Act, 1999 and the Copyright Act, 1957. A digest of the facts, the relief, and what the order tells practitioners about the interim-injunction architecture in newspaper IP matters.

Valkya Editorial··6 min
Supreme CourtSupreme Court of India

Hindustan Construction Company v. Union of India: how Section 87 fell and the no-automatic-stay regime was restored

On 27 November 2019, a three-judge bench of the Supreme Court — Rohinton Fali Nariman, J. (authoring), Surya Kant, J. and V. Ramasubramanian, J. — struck down Section 87 of the Arbitration and Conciliation Act 1996 (inserted by the 2019 Amendment) as manifestly arbitrary and violative of Article 14. The decision restored the no-automatic-stay regime built by the 2015 amendments and confirmed by BCCI v. Kochi Cricket (2018): a Section 34 challenge does not, of itself, stay the enforcement of an arbitral award; the award-debtor must apply separately for a stay under Section 36(3). A close reading of the architecture, the legislative-reversal pattern that brought Section 87 into being, the manifest-arbitrariness reasoning, and the practitioner discipline now stable on independent stay applications.

Valkya Editorial··16 min
LandmarkSupreme Court of India

Janhit Abhiyan v. Union of India: how a five-judge Bench upheld the 10 per cent EWS reservation

On 7 November 2022, a five-judge Constitution Bench held by 3:2 that the Constitution (One Hundred and Third Amendment) Act, 2019 — which had inserted clauses authorising the State to provide reservation of up to 10 per cent for economically weaker sections, additional to the existing reservation under Articles 15(4), 15(5) and 16(4) — did not breach the basic structure of the Constitution. Justices Maheshwari, Trivedi and Pardiwala wrote separate concurring opinions for the majority; Justice Ravindra Bhat wrote a dissent on behalf of himself and Chief Justice U.U. Lalit. A digest of the bench, the holdings, the dissent, and the doctrinal arc of reservation jurisprudence after the EWS judgment.

Valkya Editorial··10 min
LandmarkSupreme Court of India

Jarnail Singh v. Lachhmi Narain Gupta: creamy layer for SC/ST promotion reservation and the partial reading-down of M. Nagaraj

On 26 September 2018, a five-judge Constitution Bench held that the creamy-layer principle applies to reservation in promotion for Scheduled Castes and Scheduled Tribes — and read down the requirement, articulated in M. Nagaraj (2006), that States collect quantifiable data to demonstrate backwardness of SC/STs as a condition for providing such reservation. The unanimous judgment of Justice Nariman recalibrates the doctrinal architecture between Indra Sawhney, M. Nagaraj, and the SC/ST promotion reservation regime. A digest of the question, the holding, the doctrinal logic, and the lineage.

Valkya Editorial··8 min
Supreme CourtSupreme Court of India

Lt. Col. Pooja Pal v. Union of India: Article 142, deemed service, and the remedial finality of the Permanent Commission line

On 24 March 2026 a three-judge bench of the Supreme Court — Surya Kant CJ, Ujjal Bhuyan and N. Kotiswar Singh JJ — held that the denial of Permanent Commission to women Short Service Commission Officers across the Army, Navy and Air Force was the consequence of a structurally discriminatory evaluation framework, not of individual merit assessments. Invoking Article 142, the Court created a legal fiction of deemed completion of 20 years' qualifying service for SSCWOs released during the long litigation, preserved already-granted Permanent Commissions, and directed that serving SSCWOs meeting the 60% Selection Board cut-off be granted Permanent Commission subject to medical and disciplinary clearance. A digest of the holding, the structural-discrimination reasoning, and the Article 142 remedial architecture that closes the Babita Puniya / Annie Nagaraja / Nitisha line.

Valkya Editorial··15 min
Supreme CourtSupreme Court of India

Manish Kumar v. Union of India: the 100-allottee / 10-per-cent threshold for real-estate Section 7 IBC filings and the constitutional preservation of the Pioneer Urban architecture

On 19 January 2021 a three-judge bench of the Supreme Court — Justices Rohinton Nariman, Navin Sinha and K.M. Joseph — upheld the constitutional validity of the IBC (Amendment) Act 2020 which inserted the second proviso to Section 7(1) requiring real-estate allottees to file jointly with a minimum of 100 allottees of the same project or 10 per cent of the total allottees (whichever is less). The bench held the threshold a reasonable Article 14 classification, treated the Article 19(1)(g) and Article 21 challenges as not made out (Article 21 expressly because alternative RERA and Consumer Protection Act remedies remained available), preserved the homebuyer-as-financial-creditor status validated in Pioneer Urban (2019), and exercised Article 142 to grant a 30-day window to pending applicants to align their pleadings with the new threshold. A close reading of Justice Nariman's judgment and what the threshold means for the present practitioner advising on a real-estate Section 7 application.

Valkya Editorial··14 min
Supreme CourtSupreme Court of India

Mohd Abdul Samad v. State of Telangana: divorced Muslim women, Section 125 CrPC, and the restoration of Shah Bano

On 10 July 2024, a two-judge bench of Justices B.V. Nagarathna and Augustine George Masih held that a divorced Muslim woman is entitled to claim maintenance under Section 125 of the Code of Criminal Procedure, 1973 (now Section 144 of the BNSS, 2023) against her husband, and that the Muslim Women (Protection of Rights on Divorce) Act, 1986 operates in addition to — not in derogation of — that secular maintenance right. The judgment is the most consequential restoration of the Shah Bano line in the post-1986 period.

Valkya Editorial··8 min
High CourtDelhi High Court

Naz Foundation v. Government of NCT of Delhi: the Delhi High Court's 2009 read-down of Section 377

On 2 July 2009, a Division Bench of the Delhi High Court — A.P. Shah CJ and S. Muralidhar J — read down Section 377 of the Indian Penal Code to exclude consensual sexual acts between adults in private. The judgment articulated, for the first time in Indian constitutional law, sexual orientation as an analogous ground under Article 15, deployed Article 21 to protect sexual autonomy in the personal sphere, recast Article 14 around effect-based discrimination, and drew the distinction between constitutional morality and popular morality. The Supreme Court overruled it in Suresh Kumar Koushal in December 2013; nearly five years later, the five-judge bench in Navtej Singh Johar vindicated the reasoning. A close reading of the 2009 doctrinal moment and the procedural arc that followed.

Valkya Editorial··15 min
Supreme CourtSupreme Court of India

Shayara Bano v. Union of India: how a five-judge Bench struck down instant triple talaq

On 22 August 2017, a Constitution Bench of five judges drawn from five faiths held by 3:2 that talaq-e-biddat — the practice of instant, irrevocable triple talaq — was unconstitutional. Justice Nariman and Justice Lalit struck it down as manifestly arbitrary under Article 14. Justice Kurian Joseph struck it down on Islamic theological grounds. Chief Justice Khehar and Justice Nazeer would have left the practice to legislative reform. A digest of the bench, the three operative positions, the doctrine on manifest arbitrariness, and the subsequent Muslim Women (Protection of Rights on Marriage) Act, 2019.

Valkya Editorial··9 min
LandmarkSupreme Court of India

State of Punjab v. Davinder Singh: how a seven-judge Bench permitted sub-classification within Scheduled Castes

On 1 August 2024, a seven-judge Constitution Bench held by 6:1 that sub-classification within Scheduled Castes for reservation purposes is constitutionally permissible — and overruled E.V. Chinnaiah v. State of Andhra Pradesh (2004), which had held that the Scheduled Castes constituted a homogeneous class. The judgment recalibrates the Indra Sawhney – M. Nagaraj – Jarnail Singh line on reservation and opens the door to sub-quotas within SC reservation for the most disadvantaged sub-groups, subject to empirical data and constitutional safeguards. A digest of the bench, the opinions, the overruling of E.V. Chinnaiah, and what States can now do.

Valkya Editorial··10 min
Supreme CourtSupreme Court of India

Vineet Narain v. Union of India: continuing mandamus, CBI autonomy and the Article 32 supervisory jurisdiction

On 18 December 1997 a three-judge bench of the Supreme Court led by Chief Justice J.S. Verma, hearing the Jain hawala public interest litigation, issued a set of structural directions to insulate the Central Bureau of Investigation and the Enforcement Directorate from executive interference. The judgment fixed a two-year tenure for the CBI Director, gave the Central Vigilance Commission statutory status, struck down the 'Single Directive', and operationalised continuing mandamus as a tool of monitored investigation. It is the foundational case in modern Indian PIL practice.

Valkya Editorial··15 min
Supreme CourtSupreme Court of India

Vishaka v. State of Rajasthan: the guidelines that became the law

In the absence of a domestic statute on workplace sexual harassment, a three-judge Bench led by Chief Justice Verma framed guidelines drawn from India's international obligations and made them binding by direction. The guidelines governed for sixteen years until the 2013 POSH Act codified them. A digest of the doctrinal move, the guidelines themselves, and the relationship between the judgment and the statute it inspired.

Valkya Editorial··10 min
Supreme CourtSupreme Court of India

Joseph Shine v. Union of India: the unanimous striking down of Section 497 IPC

On 27 September 2018 — three weeks after Navtej Singh Johar — a five-judge Constitution Bench unanimously struck down Section 497 IPC, the colonial-era adultery provision that had treated the wife as the husband's property and the consenting adulterer as a thief of marital chastity. Four concurring opinions deployed the dignity and equality framework to dismantle a provision that had survived more than a century and a half of constitutional silence. A digest of the holding, the doctrinal architecture, and the relationship with the BNS framework.

Valkya Editorial··10 min
Supreme CourtSupreme Court of India

Indra Sawhney v. Union of India: the Mandal verdict, the 50% ceiling, and the creamy-layer doctrine

On 16 November 1992, a nine-judge Constitution Bench upheld the implementation of the Mandal Commission's recommendation for 27% reservation in Central Government services for Other Backward Classes — but bounded the framework with two structural constraints: reservations could not, in the aggregate, exceed 50% of available positions, and the 'creamy layer' of the backward class had to be excluded from the benefit. Three decades on, the framework remains the constitutional architecture of Indian reservations policy. A digest of the holding, the doctrinal architecture, and how it continues to govern.

Valkya Editorial··10 min
Supreme CourtSupreme Court of India

M. Nagaraj v. Union of India: the constitutional architecture of reservation in promotion

On 19 October 2006, a five-judge Constitution Bench upheld the constitutional validity of the 77th, 81st, 82nd and 85th Amendments — which together had inserted Articles 16(4A) and 16(4B) to provide for reservation in promotion for SC/ST and the carry-forward of unfilled reserved positions. The disposition articulated the three-pronged test that has governed promotion-reservation policy ever since: backwardness, inadequacy of representation, and administrative efficiency. A digest of the holding, the three-prong architecture, and the relationship with the *Indra Sawhney* and *Jarnail Singh* lines.

Valkya Editorial··10 min
Supreme Court ReferenceSupreme Court of India

Supriyo @ Supriya Chakraborty v. Union of India: the marriage-equality reference and its judicial limits

On 17 October 2023, a five-judge Constitution Bench unanimously declined to recognise a fundamental right to marry for queer persons under the constitutional framework, and declined to read down the Special Marriage Act, 1954 to extend its substantive marriage architecture to same-sex couples. A 3:2 split on the civil-union question — Chief Justice Chandrachud and Justice Kaul supporting a civil-union framework; the majority declining — produced the disposition's most substantively contested doctrinal dimension. A digest of the holding, the doctrinal architecture, and the relationship with the *NALSA* and *Navtej* lines.

Valkya Editorial··9 min