A five-judge Constitution Bench struck down a Governor's notification reserving 100% of teacher posts in Scheduled Areas for Scheduled Tribes. The Court held the measure arbitrary, in breach of the 50% ceiling from Indra Sawhney, and beyond the Governor's Fifth Schedule power, which cannot override the fundamental rights in Part III.
In 1997 a three-judge Supreme Court bench held that the grant of mining leases over land in a Fifth Schedule Scheduled Area to non-tribals is barred by the protective law, and declared such leases void. A digest of the facts, the holding on government land and the Governor's powers, and the decision's place in tribal land jurisprudence.