Reservation benefits are state-specific; migration or marriage does not transfer caste status to the host state.

The petitioner, Archana Dangi, is a native of Uttar Pradesh (UP) belonging to the 'Dangi' community, which is notified as an Other Backward Class (OBC) in UP.

She holds an OBC certificate issued by the competent authority in District Jalaun, UP.

Following her marriage to a resident of Madhya Pradesh (MP), whose community is also notified as OBC in MP, she migrated to Datia, MP.

The petitioner qualified for the Uchcha Madhyamik Shikshak Eligibility Test-2018; however, during document verification on July 3, 2020, the respondents rejected her candidature on the ground that her caste certificate was issued by another state.

The petitioner challenged this disqualification, arguing that since the 'Dangi' community is recognized as OBC in both UP and MP, she should be entitled to reservation benefits in MP following her marriage.

The court primarily relied on the principle that reservation in public services is state-specific and does not have a "Pan-India sweep".

It applied the doctrine from Bir Singh v. Delhi Jal Board (2018), which held that a person notified as a Scheduled Caste/OBC in one state cannot claim that status in another state to which they migrate.

Regarding marriage, the court followed Sobha Hymavathi Devi v. Setti Gangadhara Swamy (2005) and Sandhya Thakur v. Vimla Devi Kushwah (2005), establishing that reservation benefits are intended for the "really underprivileged" by birth and cannot be acquired through marriage.

Furthermore, the court applied the doctrine of per incuriam to disregard a conflicting coordinate bench decision (Smt. Anusuiya Prajapati v. State of M.P.) because it failed to consider binding Supreme Court precedents.

The court reasoned that the recognition of a caste as OBC is intrinsically linked to the specific social, economic, and educational backwardness faced by that community within a particular geographical territory.

Consequently, migration does not result in the "carry-over" of caste status because the degree of backwardness in the home state may not be identical in the migrating state.

The court rejected the petitioner's argument that marriage entitles a woman to her husband’s caste status for reservation purposes, clarifying that caste is determined by birth and an "advantageous start in life" cannot be bypassed by transplantation into a backward community via marriage.

The court further noted that the Petitioner's reliance on a previous Indore Bench judgment was misplaced, as that judgment was rendered per incuriam for failing to notice the Supreme Court's declarations in Bir Singh and Sobha Hymavathi Devi.

The court upheld the respondents' decision to reject her candidature, ruling that neither the common nomenclature of the caste in both states nor her marriage to an OBC resident of MP confers a right to reservation in the migrating state.

The writ petition was accordingly dismissed.