OBC Reservation Based on Birth, Not Marriage or Migration: Madhya Pradesh High Court Clarifies

Bhopal: In a significant ruling, the Madhya Pradesh High Court has reaffirmed that Other Backward Class (OBC) reservation benefits are determined by birth and cannot be claimed on the basis of marriage or migration from another state. The court also held that caste certificates issued outside the state are not valid for availing reservation benefits in Madhya Pradesh.

The judgment came while dismissing a petition filed by Archana Dangi, a native of Jalaun district in Uttar Pradesh. Dangi had successfully cleared the Higher Secondary Teacher Eligibility Test (HSTET), 2018, but her candidature was cancelled during the document verification process. The cancellation was based on the fact that her OBC certificate had been issued in Uttar Pradesh, not Madhya Pradesh.

Challenging the decision, Dangi argued that the Dangi community is recognised as an OBC in both Uttar Pradesh and Madhya Pradesh. She further contended that after her marriage, she became a resident of Madhya Pradesh and should therefore be eligible for reservation benefits in the state.

However, the state government opposed her plea, maintaining that caste identity is determined by birth and remains unchanged by marriage or relocation. It also emphasized that caste certificates issued in one state cannot be used to claim reservation in another.

Upholding the state’s position, the High Court observed that although a woman may socially adopt her husband’s caste after marriage, reservation policies are rooted in historical social and educational disadvantage tied to birth, not marital status. The ruling reinforces the principle that domicile and caste certification must align within the same state for reservation claims.

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