The Gujarat High Court has ruled that a person born into a caste that was recognized as a Scheduled Caste (SC) at the time of birth cannot be deprived of reservation benefits later merely because Parliament subsequently modifies the Scheduled Castes list. The Court dismissed a petition filed by the Employees' Provident Fund Organisation (EPFO) and upheld the promotion granted to its employee, Ranjit Vasantlal Makwana.
A Division Bench of Justice N.S. Sanjay Gowda and Justice J. L. Odedra delivered the judgment on July 17, 2026, holding that reservation benefits lawfully acquired by such an employee continue throughout service.
Background of the Case
Ranjit Vasantlal Makwana joined the EPFO as a Lower Division Clerk in 1995 under the Scheduled Caste category. At that time, the Mochi caste was recognized as a Scheduled Caste across Gujarat following the 1976 amendment to the Constitution (Scheduled Castes) Order.
In 2003, Makwana was promoted to the post of Enforcement Officer/Accounts Officer after clearing departmental examinations. However, in 2012, the EPFO reverted him to the post of Upper Division Clerk. The employer relied on the 2002 amendment, which limited Scheduled Caste status for the Mochi community in Gujarat to persons belonging to Dang district and Umbergaon taluka of Valsad district.
Makwana challenged the reversion before the Central Administrative Tribunal (CAT), which restored his promotion. The EPFO then approached the Gujarat High Court against the Tribunal's order.
Court's Observations
The High Court undertook a detailed examination of the constitutional scheme governing Scheduled Castes, including Article 341 and the historical changes to the Scheduled Castes list in Gujarat.
The Bench observed that caste is acquired by birth and remains attached to a person throughout life. It held that when an individual is born during a period in which that caste is constitutionally recognized as a Scheduled Caste, the legal consequences flowing from that recognition cannot be taken away by a later amendment.
Explaining its reasoning, the Bench observed:
"The respondent... would be entitled to all the benefits of reservation throughout his lifetime and he cannot be deprived of the benefit of reservation by the exclusion of his caste from the list of Scheduled Caste."
The Court further held that once the employee had lawfully secured appointment and later promotion on the basis of his Scheduled Caste status, those benefits formed part of his service rights. Therefore, the 2012 order withdrawing his promotion could not be sustained.
The Bench also rejected the EPFO's reliance on an earlier Supreme Court judgment concerning allotment of a dealership. It clarified that a dealership and public employment stand on different legal footing.
According to the Court, employment under the State creates vested service rights once reservation benefits are lawfully obtained, whereas the dealership case involved only a temporary benefit arising from a letter of intent.
Court's Decision
The High Court held that once the respondent was entitled to be treated as a Scheduled Caste candidate throughout his lifetime, the dispute over whether reservation should be determined on the date a vacancy arose or on the date of promotion became unnecessary.
Affirming the Central Administrative Tribunal's decision, the Court dismissed the EPFO's writ petition and upheld Makwana's promotion.
Case Details
Case Title: Employees' Provident Fund Organization & Ors. v. Ranjit Vasantlal Makwana
Case Number: R/Special Civil Application No. 21004 of 2016
Judge: Justice N.S. Sanjay Gowda and Justice J. L. Odedra
Decision Date: July 17, 2026
