MP High Court Says Migrants Cannot Claim SC Status in Another State After Marriage

In Hemlata Arya v State of Madhya Pradesh, the Madhya Pradesh High Court has held that a person migrating from one State to another cannot automatically claim Scheduled Caste benefits in the new State, even if the same caste is recognised there.

The decision was delivered by Justice Anand Singh Bahrawat of the Gwalior bench. The Court clarified that Scheduled Caste recognition is linked to the social, educational and economic backwardness faced by a community in a particular State. Such conditions may differ from one State to another.

The dispute arose from the appointment process for the post of Anganwadi Worker in Madhya Pradesh. The petitioner had applied under the Scheduled Caste category and challenged the appointment of another candidate before the Additional Collector, Sheopur.

After hearing the matter, the Additional Collector directed that the petitioner be appointed. However, respondent Kriti Sharma challenged that order before the Additional Commissioner, Morena, who later set aside the Collector’s decision and ordered a fresh appointment process after hearing all parties.

Before the High Court, the petitioner argued that her Scheduled Caste certificate issued in Rajasthan was valid throughout India. It was also argued that she had secured higher marks and deserved selection on merit under the reserved category.

The Court examined Articles 341 and 342 of the Constitution, which deal with Scheduled Castes and Scheduled Tribes in relation to specific States and Union Territories.

While deciding the case, the High Court relied on the Supreme Court judgement in Marri Chandra Shekhar Rao Vs. Dean, Seth G.S. Medical College. The Supreme Court had earlier ruled that caste recognition is State-specific because the degree of backwardness may vary across different regions.

The High Court reiterated that a person recognised as belonging to a Scheduled Caste in one State does not automatically get the same status after moving to another State. The bench also observed that only certain historic migrations before 1950 were treated differently under constitutional provisions.

In the present matter, the Court noted that the petitioner had migrated to Madhya Pradesh after marriage and possessed a caste certificate issued by Rajasthan. Therefore, she could not claim Scheduled Caste reservation benefits in Madhya Pradesh.

The Court directed the authorities to conduct the Anganwadi Worker appointment process strictly on merit without extending Scheduled Caste reservation benefits to the petitioner. It also directed that all parties should be given a personal hearing before a final decision is taken.

The writ petition was dismissed, and the authorities were directed to complete the process within three months.