HC rules candidates exceeding OBC income limit fall under creamy layer, ineligible for 2A quota

Bengaluru: In a significant ruling affecting reservation entitlements in Karnataka, the High Court has clarified that candidates whose parents’ annual income crosses the prescribed limit under the Category 2A (Backward Classes) quota must be treated as part of the creamy layer, making them ineligible to claim reservation benefits.

A Division Bench headed by Chief Justice Vibhu Bakhru, which was hearing a batch of petitions including a writ appeal (WA 301/2025 GM-CPC) and a contempt plea (CCC 74/2025), delivered the order while overturning an earlier judgment of a single-judge bench.

The appeal was filed by the Caste and Income Verification Appellate Authority of the Backward Classes Welfare Department and the Chairman of the Dharwad District Caste and Income Verification Committee, challenging the previous decision that had held a candidate eligible for 2A reservation despite exceeding the income limit.

Court accepts government’s argument

The Division Bench accepted the submissions made by government counsel Namita Mahesh, who argued that the income of the parents — “from all sources, including salary components” — must be taken into account while determining creamy layer eligibility.

In its order, the Bench stated:

“The income of the parents, including salary and all other sources, must be considered. If the annual income exceeds the prescribed limit, and if the parents are income-tax payers, the candidate unquestionably falls under the creamy layer. Consequently, he or she cannot claim reservation under Category 2A.”

The court emphasized that the creamy layer principle is meant to prevent relatively affluent sections of backward classes from availing benefits meant for genuinely backward communities.

Background of the case

The case pertains to Raghavendra Fakkirappa Chandrannavar of Dharwad, who had applied for the post of Assistant Engineer in KPTCL under the Kuruba community (Category 2A). He was selected under the reservation quota and subsequently applied for the caste-and-income certification required to finalize his appointment.

However, the Dharwad District Verification Committee rejected his request, stating that his parents’ income exceeded the ₹8 lakh annual limit, which is the ceiling specified for availing reservation under 2A.

According to the committee, the income recorded placed the family in the creamy layer, making the candidate ineligible for backward-class reservation.

Following this, Raghavendra approached the High Court. In October 2024, a single-judge bench ruled in his favor, declaring that he was eligible for reservation benefits.

Challenging this ruling, the State government moved a writ appeal before the Division Bench, arguing that the single-judge bench had overlooked the mandatory income-based criteria that determine creamy layer status.

Bench overturns earlier ruling

The Division Bench agreed with the State’s arguments and categorically set aside the earlier order:

“A candidate whose parental income exceeds the stipulated ceiling cannot be considered backward for the purpose of reservation. The earlier judgment failed to appreciate the binding principles governing creamy layer assessment.”

The ruling reinforces the principle that reservation benefits under backward-class categories cannot be extended to individuals from economically advanced families, even if they belong to backward castes.

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