M.R. Balaji vs State of Mysore, 1963

•  In this case The State issued an order on 26th July 1958, that all the communities excepting the Brahmin community, 75% seats are reserved including schedule caste and schedule tribes for them as these are educationally and socially backward.
• They passed another order after that on 31st July , 1962 which is for engineering and medical Colleges on the basis of religion, race and caste in which 68% seats are reserved and 32% unreserved seats. They classified the backward classes into two categories backward classes and more backward classes .
• Later this order was challenged under article 32 through a writ petition before the supreme court saying it is fraud on Article 15(4) . They claim that the classification made by the state of 68% reservation was irrational and fraud as it is infringing their Fundamental Rights. So the reservation for socially and backward classes for Schedule caste and schedule tribes and 32% seats are left for the merit pool.
• There are 23 Petitioners before the Supreme court out of which 6 petitioners were applicants for admission in Medical Colleges. So the order was challenged by a more marks secured candidates as they failed to get admission because of the government reservation order. 

• Whether the caste is sole factor for deciding backwardness of classes?
• Whether test adopted by the state to measure educational backwardness permissible?
• Whether the categorization into Backward class and more backward class permissible?
• What is the extent of reservation that can be made under Article 15(4)?

• The court decided in this case that the questioned order was an abuse of the constitutional authority given to the State through Article 15(4) and should be nullified. The order separated the backward classes solely based on their caste, which is not allowed by Article 15(4). The reservation of 68% of seats goes against the idea of the special provision permitted by Article 15(4). 
• However, the court in MR Balaji v State of Mysore refrained from setting a fixed and strict percentage for reservations, emphasising that reservation must aid the progress of marginalised sections of society. But care should be taken not to exclude well-qualified candidates from other communities.
• Reservations under Articles 15(4) and 16(4) must remain within reasonable boundaries. Balancing the interests of weaker sections, which have priority, with the interests of the whole community is crucial. Generally, a special provision should be below 50%, but the exact percentage should vary based on the specific circumstances of each case.
• The court held in this case that the purpose of Article 15(4) is to enhance the overall welfare of society by safeguarding the interests of its vulnerable elements. Any provision under Article 15(4) that disregards society’s welfare is beyond its scope. It’s highly unreasonable to assume that when creating Article 15(4), the Parliament intended to ignore the fundamental rights of citizens who are part of the rest of society while advancing the backward classes and Scheduled Castes and Tribes. National interests and the welfare of the entire community must always be considered.

In this Case The supreme court mentioned the important criteria of reservation that the reservation should be provided to the weaker sections of the society in order to advance and uplift the weaker sections and not be done by cutting the interest of the remaining sections of the society. Under Article 15(4) backwardness must be both social and educational and not either social or educational and categorization of backward classes into backward and more backward is not warranted by Article 15(4) and was a fraud on Article 15(4) of the constitution. The reservation of 68% is inconsistent with the provisions of Article 15(4) . Therefore the Supreme Court limits the reservation to 50% and reservation must not exceed 50% in any case and threw light on the importance of national interest above all to not affect the qualified students to not take admissions in the institutions of higher and technical education for the sake of reservation. So the sole basis for determining whether a caste is backward or not will only be on the basis of socially and educationally backward classes and not on the basis of caste.