Migrant OBC candidates cannot claim reservation benefits in the transferee State based on home State caste certificates.

The petitioners, Smt. Sadhna Sahu and Vinita Sahu, were originally residents of Uttar Pradesh (U.P.) belonging to the Sahu community, which is notified as Other Backward Classes (OBC) in U.P.

Both migrated to Madhya Pradesh (M.P.) following their marriages to residents of M.P. whose community is also recognized as OBC in M.P.

The petitioners qualified for the Middle School Teachers Eligibility Test-2018; however, during document verification, the District Education Officer, Ashoknagar, rejected their candidatures on the ground that their OBC certificates were issued by the State of Uttar Pradesh rather than the State of M.P.

The petitioners challenged this disqualification and the state circulars dated 11.07.2011 and 13.01.2014 which restricted reservation benefits to native residents.

1. Whether a person who migrates from one State to another is entitled to claim the benefit of reservation in the migrating State based on a caste certificate issued by the home State, even if the caste is recognized as OBC in both States.

2. Whether migration by marriage entitles a person to the caste status of the spouse for the purpose of public employment reservation.

The Court applied the principle that reservation in public services is state-specific and not "Pan India" in scope.

It relied on the Division Bench judgment in Seema Devi v. Union of India and Ors. (2024 (2) MPLJ 71), which held that a migrant does not carry their caste status to the migrating State because social and economic backwardness is geographically relatable to the home State.

Furthermore, the Court applied the Supreme Court’s ruling in Bir Singh v. Delhi Jal Board (2018) 10 SCC 312, establishing that benefits under Articles 341 and 342 are confined to the geographical territories specified in Presidential Orders.

It also reaffirmed that caste is determined by birth and not by marriage.

The Court reasoned that the recognition of a caste as OBC is strictly linked to the specific social and educational backwardness faced by that community within a particular State.

Merely because a caste shares a name across two States does not equate to identical levels of backwardness.

The Court rejected the argument that marriage confers caste benefits in the migrating State, noting that the petitioners’ status must be determined by birth in their State of origin.

Since the petitioners moved from U.P. to M.P., they attained the status of migrants who cannot carry their specific OBC status for the purpose of seeking reservation in M.P. public services.

The Court emphasized that under Article 141, the Supreme Court's interpretation in Bir Singh—limiting reservation benefits to the State of origin—is binding.

The Court upheld the actions of the respondents and the validity of the state instructions.

Consequently, both writ petitions were dismissed.