Meaning
The Justice H.N. Nagamohan Das Commission was a one-man commission set up by the Government of Karnataka to study and recommend internal reservation among Scheduled Castes in the state.
It became important after the Supreme Court’s judgment in State of Punjab v. Davinder Singh, 2024, which allowed sub-classification within SC/ST categories if it is based on proper data and constitutional principles.
Background
For many years, several Scheduled Caste communities in Karnataka argued that the benefits of reservation were not equally distributed among all SC groups.
Some communities claimed that relatively better-represented SC groups were getting a larger share of jobs and educational opportunities, while the most marginalised sub-castes remained underrepresented.
This led to the demand for internal reservation, meaning reservation within the SC quota itself.
The Karnataka government appointed retired Justice H.N. Nagamohan Das to examine this issue and suggest a data-based formula.
Purpose of the Commission
The commission was asked to study whether internal reservation should be provided among Scheduled Castes in Karnataka.
Its work focused on:
- Social backwardness of different SC sub-groups
- Educational backwardness
- Representation in government jobs
- Distribution of reservation benefits
- Population share of different SC communities
- Need for sub-classification within the SC quota
The idea was to ensure that reservation benefits reach the most deprived communities within the SC category.
Survey and Data Collection
The commission prepared a detailed report based on a large survey.
According to reports, the final report was around 1,766 pages.
The survey covered about 27.24 lakh families and around 1.07 crore individuals in Karnataka. The data was collected through a mobile application and government records.
This was important because the Supreme Court had made it clear that sub-classification cannot be arbitrary. It must be based on empirical data.
Recommendations
The commission recommended internal reservation within the Scheduled Caste quota in Karnataka.
Reports stated that the commission proposed classification of SC communities into multiple groups based on relative backwardness and representation.
One reported formula suggested reservation distribution within a proposed 17% SC quota as:
- 6.5% for SC Left communities
- 5.5% for SC Right communities
- 4% for other “untouchable” communities
- 1% for nomadic and smaller SC communities
The exact government implementation later differed from the commission’s recommendation.
Government Response
The Karnataka government accepted the commission’s report with modifications.
In August 2025, the cabinet accepted the report but modified the recommendation of five categories into three categories: A, B and C. The government order reportedly provided 6% each for SC Left and SC Right groups, and 5% for other SC communities within a 17% structure.
However, the matter continued to evolve due to legal and policy concerns.
In April 2026, the Karnataka cabinet approved a revised internal reservation formula within the existing 15% SC quota. The revised formula was:
- 5.25% for Category A
- 5.25% for Category B
- 4.5% for Category C
This was linked to concerns around the overall reservation ceiling and pending legal issues.
Constitutional Context
The commission’s relevance is directly connected with the Supreme Court’s 2024 judgment in State of Punjab v. Davinder Singh.
That judgment held that:
- SC/ST communities are not necessarily homogeneous.
- States can create sub-classification within SC/ST categories.
- Such sub-classification must be based on empirical data.
- The state cannot add or remove castes from the Presidential List.
- The objective must be substantive equality.
The Nagamohan Das Commission attempted to provide the empirical basis required for such sub-classification in Karnataka.
Significance
The commission is significant because it represents a shift from general reservation to more targeted reservation.
Its importance lies in the following points:
- It addressed unequal distribution of benefits within the SC category.
- It used large-scale data collection for policy-making.
- It attempted to align state policy with the Supreme Court’s 2024 ruling.
- It gave a framework for internal reservation in Karnataka.
- It highlighted the idea of substantive equality within disadvantaged groups.
- It revived a long-standing demand of several SC sub-castes.
Criticism and Concerns
The commission and its implementation also raised concerns.
Some groups argued that the formula did not properly reflect their population share or backwardness.
Political parties also criticised the government for modifying the commission’s recommendations.
Concerns include:
- Possible political use of sub-classification
- Competition among SC sub-groups
- Difficulty in measuring backwardness accurately
- Legal challenges over quota limits
- Risk of fragmenting Dalit politics
- Disputes over data quality and category placement
The BJP criticised the revised 2026 formula, arguing that the government ignored earlier recommendations, including the Nagamohan Das Commission’s higher allocations.
Present Status
As of April 2026, Karnataka has approved a revised internal reservation formula within the existing 15% SC quota.
The formula gives 5.25% each to two major SC sub-groups and 4.5% to the remaining category.
The decision is expected to allow stalled recruitment for around 56,000 government posts to move forward.
Conclusion
The Justice H.N. Nagamohan Das Commission is important because it provided a data-based foundation for internal reservation among Scheduled Castes in Karnataka.
Its work reflects the larger shift in Indian reservation policy from treating SCs as a completely uniform category to recognising internal inequalities within the group.
However, the issue remains sensitive. Internal reservation can promote fairer distribution of benefits, but it must be based on reliable data, transparent criteria and constitutional safeguards to avoid political misuse and social fragmentation.
