Migrants cannot claim OBC reservation benefits in a different State despite the caste sharing the same name.

The petitioners, originally residents of Uttar Pradesh (U.P.), belong to the Sahu community, which is notified as an Other Backward Class (OBC) in U.P.

They hold OBC certificates issued by the competent authority in District Lalitpur, U.P.

Following their marriages to residents of Madhya Pradesh (M.P.)—whose community is also recognized as OBC in M.P.—the petitioners migrated to M.P.

Both 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 another State.

The petitioners challenged the rejection and the validity of GAD circulars dated 11.07.2011 and 13.01.2014.

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 same caste is recognized as OBC in both States?

2. Whether the petitioners, by virtue of marriage to persons belonging to an OBC category in M.P., are entitled to be treated as members of the OBC category in the State of M.P.?

The Court applied the constitutional principle that reservation in public services is State-specific and not a Pan-India right.

It relied on Articles 341 and 342 of the Constitution of India regarding the Presidential Orders for Scheduled Castes and Tribes, which are notified separately for each State.

The primary precedents included the Supreme Court decision in Bir Singh v. Delhi Jal Board (2018) 10 SCC 312, which established that a person notified as a reserved category member in State 'A' cannot claim that status in State 'B' for employment.

Furthermore, it applied the Division Bench ruling in Seema Devi v. Union of India and Ors. (2024) 2 MPLJ 71, affirming that caste status is determined by birth and geographical backwardness in the home State, not by marriage or migration.

The Court reasoned that the recognition of a caste as OBC is strictly related to the social, economic, and educational backwardness existing within the specific geographical boundaries of the home State.

Merely sharing a caste name across two States does not equate to identical backwardness.

Therefore, migration does not transport caste status to the new State.

On the issue of marriage, the Court held that caste is determined by birth; migrating to M.P. after marrying an OBC resident of M.P. does not grant the petitioners OBC status within M.P. for the purposes of public employment.

The court noted that because the petitioners’ certificates were issued by U.P., they are ineligible for reservation benefits in M.P. under prevailing legal standards and executive instructions.

The action of the respondents in rejecting the petitioners' candidatures was upheld as just and proper.

Consequently, both writ petitions were dismissed.