The Allahabad High Court directed the Uttar Pradesh government and the State Election Commission to complete village panchayat elections within three months. The court ruled that the polls cannot wait for a commission that is studying backwardness among Other Backward Classes (OBCs). A Division Bench of Justice Ajit Kumar and Justice Garima Prashad decided a batch of petitions, including one filed by Dashrath Yadav.
The term of Uttar Pradesh’s elected panchayats ended in May 2026. The State Election Commission submitted that the final electoral roll had been published on June 10, 2026, but the election process did not move forward after that date. On May 18, the state had constituted a Dedicated Backward Classes Commission to collect empirical data on the backwardness of OBCs. On May 25, the state appointed outgoing village heads, known as Pradhans, as Administrators.
The petitioners said the delay breached Article 243-E of the Constitution. That provision fixes a panchayat’s term at five years and requires fresh polls before the term ends. The State wanted the court to wait for the commission’s report. The commission said about 60 per cent of its survey was done.
The case turned on the Supreme Court’s “triple test” for OBC reservation in local body elections, explained in K. Krishna Murthy (2010) and reiterated in Vikas Kishanrao Gawali (2021). The test requires:
- Dedicated commission: The State must establish a dedicated commission to conduct a rigorous, contemporaneous empirical inquiry into OBC backwardness in local bodies.
- Local body-wise reservation: The proportion of OBC reservation must be determined separately for each local body, based on the commission’s recommendations, to avoid excessive reservation.
- 50 per cent ceiling: Total vertical reservation for Scheduled Castes, Scheduled Tribes and OBCs together must not exceed 50 per cent.
The Bench examined the Commission’s survey process using the material submitted for Agra, where the rural population was recorded at over 25 lakh. The records showed that 175 residents attended a meeting, 29 filled in forms and statements were separately recorded from 47 people. The Court found that the material presented so far had not, prima facie, demonstrated compliance with the Supreme Court’s requirements for empirical assessment and local-body-wise justification. It clarified that the eventual report’s validity remained open to scrutiny. The Court observed:
“Supreme Court has already held provision as contained under Article 243-E to be mandatory and so the law applies to Section 12(3) of Panchayat Raj Act, 1947 as well, and neither the State government, nor the State Election Commission can defer/postpone the elections beyond the expiry of the full term of the Panchayat bodies, or in case of premature dissolution, beyond six months from the date of dissolution of panchayat bodies in the name of awaited report of a dedicated Commission.”
On the constitutional challenge, the Bench found no sufficient basis to declare Sections 12(3-A) and 12-BB(3) invalid under Article 243-E of the Constitution.
The High Court directed the Uttar Pradesh government and State Election Commission to complete Panchayat elections within three months under the existing reservation framework, including 27% OBC quota.
The Court also ordered the government to provide necessary election support and directed the dedicated commission to continue its inquiry. However, it rejected challenges to the appointment of outgoing Pradhans as administrators and the validity of the relevant statutory provisions.
Case Title: Dashrath Yadav v. State of Uttar Pradesh and 3 Others (with connected petitions)
Case Number: Writ-C No. 22590 of 2026
Judges: Justice Ajit Kumar and Justice Garima Prashad
Decision Date: October 14, 2026
