Madhya Pradesh High Court Holds Scheduled Caste Benefits Cannot Be Claimed Outside Home State

In Smt. Hemlata Arya v. State of Madhya Pradesh & Ors., the Madhya Pradesh High Court reaffirmed that Scheduled Caste reservation benefits are state-specific and cannot automatically extend to a person who migrates from another State, even if the caste is recognised in both States.

Justice Anand Singh Bahrawat was hearing a petition filed by Hemlata Arya, who challenged an order directing reconsideration of appointments to the post of Anganwadi Worker in Sheopur district. Arya had claimed appointment under the Scheduled Caste category on the basis of a caste certificate issued in Rajasthan.

The petitioner argued that her certificate was valid throughout India and that she was more meritorious than the selected candidates. However, the State contended that since her caste certificate was issued by authorities in Rajasthan, she could not claim reservation benefits in Madhya Pradesh.

Accepting the State’s stand, the Court held that reservation benefits remain linked to a person’s “home State.” Relying on Supreme Court decisions including Marri Chandra Shekhar Rao v. Dean, Seth G.S. Medical College, Action Committee v. Union of India, and Bir Singh v. Delhi Jal Board, the Court observed that social and educational backwardness varies from State to State, and therefore reservation benefits cannot travel with migration.

The Court also referred to earlier Madhya Pradesh High Court rulings dealing with migration after marriage. It ultimately directed authorities to reconsider the appointment process while treating the petitioner as ineligible for Scheduled Caste reservation benefits in Madhya Pradesh.