A migrant cannot claim reservation benefits in a State other than their State of origin.

Respondent No. 6, born in District Chandauli, Uttar Pradesh (U.P.), was issued a Scheduled Caste certificate by the Tehsildar of Sakaldiha (U.P.) on 11.09.2015.

He subsequently obtained a second caste certificate from Tehsildar Doiwala, Uttarakhand, on 14.12.2016.

Utilizing the 2015 U.P. certificate, he secured an appointment as a Forest Guard under the Scheduled Caste quota of Uttarakhand.

Although this appointment was initially cancelled in 2017, the Chief Conservator of Forests upheld the appointment via an order dated 24.08.2019, reasoning that the respondent was entitled to the benefit.

The petitioner, a co-competitor in the selection process, challenged this order, contending that a migrant cannot claim reservation benefits in a Successor State.

1. Whether a person belonging to a Scheduled Caste or Scheduled Tribe can claim the benefit of reservation in a State other than their State of origin upon migration.

2. Whether the appointment of Respondent No. 6, based on a caste certificate from the State of Uttar Pradesh against a vacancy reserved for the State of Uttarakhand, is legally sustainable.

The Court applied the constitutional principle that reservation benefits are state-specific and do not travel with the migrant.

It relied on the Division Bench judgment in Smt. Ranjana Kumari v. State of Uttaranchal, which established that rights as a Scheduled Caste member accrue at birth and are affixed to the State of origin.

Constitution Bench decisions in Marri Chandra Shekhar Rao v. Dean, Seth G.S. Medical College and Action Committee on Issue of Caste Certificate to SC/ST v. Union of India held that recognition of a caste in a migrant State does not entitle a person to reservation benefits in that State.

The Court also referenced WPSB No. 462 of 2025, affirming that a person cannot have two States of origin for the purpose of reservation.

The Court observed that the State of origin for Respondent No. 6 is indisputably Uttar Pradesh, as evidenced by his birth in Chandauli and the initial caste certificate issued there in 2015.

The Court rejected the respondent's argument that his residence in Dehradun since birth or his father's employment there altered his status, noting that there was no evidence the original U.P. certificate was ever cancelled.

Applying the cited precedents, the Court reasoned that the "rigours of the Constitution Bench Judgments" cannot be diluted by the subsequent issuance of a certificate by the migrant State (Uttarakhand).

Since the respondent’s status is affixed to his State of origin (U.P.), he is legally ineligible to occupy a post reserved for the Scheduled Castes of the State of Uttarakhand.

The Court set aside the impugned order dated 24.08.2019 passed by the Principal Chief Conservator of Forests.

The Principal Chief Conservator was directed to reconsider the matter in light of the Supreme Court's declarations; should the decision go against Respondent No. 6, the petitioner is granted liberty to stake a claim for the appointment through a formal representation.