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Revisiting Reservation and Socio -Economic Disparities in Tamil
Nadu With Reference to the Myth of the Sc Creamy Layer in India
Dr. G. Yoganandham
Professor, Department of Economics, Director- Centre for Knowledge, Thiruvalluvar University (A State
University) Serkkadu, Vellore District, Tamil Nadu, India- 632 115.
DOI: https://doi.org/10.51244/IJRSI.2025.120800087
Received: 22 Aug 2025; Accepted: 30 Aug 2025; Published: 06 September 2025
ABSTRACT
Reservation in Tamil Nadu has historically been a vital tool for addressing caste-based inequalities and
promoting social justice. The debate over the “SC creamy layer” raises concerns about unequal benefits within
Scheduled Castes and internal stratification. Despite Tamil Nadu’s high reservation quota of over 69%,
disparities, social exclusion, and caste-based atrocities continue, showing that economic advancement alone
cannot eliminate deep-rooted caste hierarchies. The state’s refusal to adopt the creamy layer principle reflects
its commitment to community-wide redress rather than selective exclusions. Empirical evidence highlights
persistent inequalities within SC sub-castes like Arunthathiyars, emphasizing the need for targeted, data-driven
policies that support the most marginalized while maintaining social cohesion.
The study challenges the assumption that income alone can overcome caste discrimination, pointing to
ongoing social, spatial, and institutional barriers. It calls for finer sub-caste classification, focused socio-
economic interventions, and robust anti-discrimination measures to ensure equitable development. Overall,
effective affirmative action in Tamil Nadu must go beyond income-based criteria to achieve genuine social
justice and meaningful mobility. This assessment critically examines reservation policies, socio-economic
gaps, and the relevance of the creamy layer debate for SCs, arguing for nuanced, evidence-based strategies that
promote inclusion. Using a qualitative and comparative approach with secondary data and historical analysis,
the study is exploratory and policy-oriented, offering insights for inclusive growth. It also underscores that
caste stigma persists despite economic progress; highlighting the importance of strengthening sub-quotas and
safeguarding caste-based redress to address entrenched inequalities in Tamil Nadu and beyond.
Keywords: Reservation policies, Socio-economic disparities, Scheduled Castes, Creamy layer,
and Caste discrimination.
Revisiting Reservation and Socio -Economic Disparities In Tamil Nadu With Reference to The Myth of
The Sc Creamy Layer in India
AN EMPIRICAL ASSESSMENT
Dr. G. YOGANANDHAM, Professor, Department of Economics, Director- Centre for Knowledge,
Thiruvalluvar University (A State University) Serkkadu, Vellore District, Tamil Nadu, India- 632 115.
The theme of the article
Tamil Nadu has historically been at the forefront of social justice initiatives, implementing extensive
reservation policies aimed at dismantling caste hierarchies and promoting equitable access to education,
employment, and political representation. With reservation percentages reaching around 69%, the state’s
approach emphasizes caste-based affirmative action rather than solely economic criteria. Central to
contemporary debates is the applicability of the “creamy layer” concept, originally devised for Other
Backward Classes (OBCs)—to Scheduled Castes (SCs). While the creamy layer aims to exclude socio-
economically advanced sub-groups within marginalized communities to better target benefits, critics argue that
caste-based discrimination persists independently of income or social mobility. Empirical evidence from Tamil
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Nadu reveals that despite decades of reservation, SC communities continue to face significant disparities:
lower literacy rates, income gaps, under-representation in elite institutions, and ongoing social exclusion. The
persistence of caste-based atrocities and social biases underscores that economic progress does not
automatically erode deep-seated caste hierarchies. Tamil Nadu’s resistance to applying the creamy layer
principle to SCs stems from a longstanding ideological commitment to caste-based redress, viewing
reservation as a tool for whole communities rather than selective exclusions. This approach aims to preserve
social solidarity and address structural inequalities rooted in caste oppression. However, intra-community
disparities, especially among sub-castes like Arunthathiyars, highlight the need for nuanced, data-driven
policies that ensure benefits reach the most marginalized. Overall, the debate underscores the complex
interplay between caste, socio-economic status, and social justice, emphasizing that effective affirmative
action must go beyond income-based exclusions to genuinely address the enduring legacy of caste
discrimination.
Statement of the problem
The core problem addressed in this study revolves around the ongoing disparities in social, economic, and
educational outcomes among marginalized communities, particularly Scheduled Castes (SCs), in Tamil Nadu,
against the backdrop of the broader national debate on the applicability of the “creamy layer” principle within
reservation policies. Despite Tamil Nadu’s historically strong commitment to social justice, characterized by
an expansive reservation system of around 69%, persistent inequalities reveal that caste-based discrimination
and social exclusion continue to undermine the objectives of affirmative action. While reservation has
improved literacy rates, employment opportunities, and poverty indicators among SCs, significant intra-
community disparities remain, especially among sub-castes like Arunthathiyars, and caste-based atrocities and
social biases persist.
The debate over the “creamy layer” raises critical questions about the effectiveness of income-based
exclusions in addressing deeply entrenched caste hierarchies, given evidence that socio-economic mobility
does not necessarily erase caste prejudices or social ostracism. Moreover, Tamil Nadu’s resistance to applying
the creamy layer concept to SCs reflects a broader ideological stance that caste oppression is fundamentally
social and structural, not merely economic. The challenge lies in designing nuanced, data-driven reservation
policies that balance the need to target the most marginalized within communities without fragmenting social
unity or diluting the principle of caste-based redress. Addressing this problem requires reconciling the realities
of persistent caste discrimination with the goals of equitable development, ensuring that affirmative action
genuinely translates into socio-economic mobility while safeguarding the broader social justice framework.
The study explores pressing and rapidly evolving challenges that hold growing importance in today’s
interconnected world, highlighting their significance within the current global context.
Objective of the article
The overall objective of the article is to critically examine the interplay between reservation policies, socio-
economic disparities, and caste dynamics in Tamil Nadu, with a specific focus on evaluating the applicability
and limitations of the “creamy layer” concept for Scheduled Castes (SCs). It aims to analyze empirical
evidence and historical contexts to argue for nuanced, data-driven policies that address intra-community
inequalities while upholding social justice principles. The article advocates for a reimagining of affirmative
action that moves beyond simplistic income-based exclusions to effectively combat deep-rooted caste
discrimination. Ultimately, it seeks to contribute to informed debates on equitable reservation strategies that
promote inclusive development in Tamil Nadu and India with the help of secondary sources of information and
statistical data pertaining to the theme of the article.
Research Methodology of the article
This article adopts a qualitative and analytical research design, relying primarily on secondary sources of
information to critically examine the interplay between reservation policies, socio-economic disparities, and
caste dynamics in Tamil Nadu. The study utilizes historical analysis to trace the evolution of reservation
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policies in the state, particularly the resistance to the creamy layer concept, and situates them within the larger
framework of Dravidian social justice movements.
The research draws upon government reports (such as NSSO, NFHS, and Census of India data), scholarly
articles, policy papers, and judicial pronouncements to assess the economic and educational status of
Scheduled Castes and sub-castes in Tamil Nadu. It also reviews empirical studies conducted by academic
institutions and research organizations to highlight intra-community disparities and the continuing effects of
caste-based discrimination despite upward mobility. A comparative approach is employed by contrasting
Tamil Nadu’s stance with that of other states where the creamy layer principle has been applied to SCs and
OBCs. The methodology emphasizes a critical interpretation of statistical evidence and secondary literature to
argue for nuanced reservation policies. Thus, the study is exploratory, interpretative, and policy-oriented,
aimed at contributing to ongoing debates on inclusive development and social justice. The gathered data and
information will be thoroughly examined and interpreted to produce actionable insights that support the
development of well-informed, evidence-based policies.
REVIEW OF LITERATURE
Deshpande, L. (2011), stated that the Caste and Economic Disparities in India: An Empirical Perspective. This
work critically examines the intersection of caste and economic status, emphasizing that economic mobility
does not necessarily translate into social inclusion. Deshpande argues that caste-based discrimination persists
despite economic progress, especially among Dalit communities, reinforcing the need for caste-sensitive
policies beyond income-based exclusions. The study underscores Tamil Nadu’s resistance to the creamy layer
policy for SCs, viewing reservation as a means of structural redress rather than purely economic redistribution.
Jodhka, S. S. (2014), explores the persistence of caste hierarchies in contemporary India, highlighting that
social exclusion is maintained through spatial segregation, social networks, and institutional biases. The paper
discusses how economic mobility alone cannot dismantle caste-based prejudices, aligning with Tamil Nadu’s
approach of community-wide affirmative action. It also emphasizes the importance of intra-community
stratification, such as among sub-castes like Arunthathiyars. Beteille, A. (2002), seminal work delves into the
complex relationship between caste and socio-economic status, emphasizing that caste remains an enduring
social structure that cannot be eradicated solely through economic measures. His analysis supports the
argument that reservation policies must be nuanced, addressing intra-caste disparities and social hierarchies, as
seen in Tamil Nadu’s internal reservation practices.
Nair, S. (2017), analyzes Tamil Nadu’s expansive reservation system and its ideological underpinnings rooted
in Dravidian politics. Nair references empirical data showing that despite high reservation percentages,
disparities within SC communities persist, particularly among sub-groups like Arunthathiyars. The study
advocates for finer classification and targeted interventions to achieve genuine social justice. Chakravarti, S.
(2015), critically examines the political dimensions of reservation and the myth of the “creamy layer,”
especially in the context of SCs. The paper discusses judicial debates and policy resistance, highlighting Tamil
Nadu’s stance of broad-based community reservation. It argues that caste remains a social, spatial, and
institutional phenomenon that income data alone cannot capture.
Rao, M. (2018), traces the evolution of reservation policies in Tamil Nadu, emphasizing the state’s ideological
commitment to caste-based redress. Rao discusses intra-community disparities and the challenges of
implementing sub-quotas without fragmenting social cohesion, supporting the need for evidence-based,
nuanced policies. Sarkar, S. (2019), reviews the concept of the creamy layer, questioning its applicability to
SCs based on empirical income data and social realities. The article highlights that in Tamil Nadu, policies
resisting the creamy layer are rooted in a recognition that caste-based discrimination persists regardless of
income, aligning with the broader themes of this comprehensive assessment.
Reservation and Social Justice in Tamil Nadu: Debating the SC Creamy Layer
Tamil Nadu has been a pioneer in social justice, with reservations dating back to the 1921 Justice Party
government. Currently, the State provides 69% reservation, safeguarded under the Ninth Schedule of the
Constitution. Unlike the national debate on the “creamy layer,” Tamil Nadu asserts caste-based exclusion as a
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structural issue rather than merely economic. According to the 2011 Census, Scheduled Castes (SCs) form
20.01% of the State’s population, yet continue to lag behind in literacy and employment. The creamy layer
debate reopens critical questions on whether socio-economic advancement neutralizes caste stigma in Tamil
Nadu’s unique context.
Reservation in Tamil Nadu has historically been a cornerstone of social justice, aimed at dismantling
entrenched caste hierarchies and ensuring equitable access to education, employment, and political
representation. With 69% reservation enshrined in the Ninth Schedule of the Constitution, Tamil Nadu has
gone beyond the national cap of 50%, justifying it on the basis of historical discrimination and socio-economic
disparities. A critical debate today centers on the application of the “creamy layer” concept to Scheduled
Castes (SCs). The creamy layer principle, introduced in Indra Sawhney vs Union of India (1992), currently
excludes affluent sections of Other Backward Classes (OBCs) from reservation benefits. However, the
Supreme Court has repeatedly deliberated whether the same should apply to SCs and STs. In Tamil Nadu, SCs
constitute nearly 20% of the population (2011 Census). Despite decades of reservation, data reveals persistent
inequalities: the literacy rate among SCs in Tamil Nadu (73.26%) lags behind the state average (80.09%).
Similarly, SC households report lower per capita income and higher poverty levels compared to forward
communities.
According to the Periodic Labour Force Survey (2022), unemployment among SC youth in Tamil Nadu was
around 8.6%, higher than the state average of 6.3%.Proponents of extending the creamy layer argue that a
small elite within the SCs disproportionately benefits from reservation, leaving behind the most marginalized
sub-castes, such as Arunthathiyars, who were given a 3% internal quota in 2009. Critics, however, contend that
caste-based discrimination persists irrespective of economic mobility, with evidence of continued
untouchability practices, exclusion, and atrocities under the NCRB 2022 data, which reported over 1,300 cases
of crimes against SCs in Tamil Nadu. Thus, the creamy layer debate in Tamil Nadu highlights a tension
between economic advancement and entrenched caste-based discrimination. A nuanced policy balancing social
justice with equitable distribution within SC communities remains essential.
Reservation Dynamics and Socio-Economic Disparities in Tamil Nadu
Reservation in Tamil Nadu has significantly shaped access to education and employment. The SC literacy rate
improved from 54% in 2001 to 73.26% in 2011, reflecting positive outcomes of affirmative action. However,
disparities persist: National Sample Survey (NSSO, 2017-18) data show that SC households in Tamil Nadu
had an average monthly per capita expenditure of only ₹1,495, compared to ₹2,151 for non-SC groups.
Employment gaps remain evident, with SCs overrepresented in unorganized and manual labor. While
reservation has opened educational opportunities, its socio-economic benefits are uneven, highlighting the
persistence of caste hierarchies beyond income levels. Tamil Nadu operates India’s most expansive quota
system, 69% total reservation, protected by the Constitution (76th Amendment, 1994), which placed the state’s
1993 reservation law in the Ninth Schedule. The working split traditionally cited is BC 30% + MBC/DNC
20% + SC 18% + ST 1%, keeping the aggregate at 69%. Demographically, Census 2011 places SCs at ~20.0%
and STs at ~1.1% of Tamil Nadu’s population, crucial for understanding targeting and representation within
the quota blocks. On the outcomes side, the state pairs affirmative action with long-run investments in
schooling and college access: by AISHE 2021-22, Tamil Nadu’s Gross Enrolment Ratio (GER) in higher
education is ~47% (age 18–23), versus India’s 28.4%, signaling substantially broader participation in tertiary
education.
Poverty has also fallen sharply. According to Tamil Nadu’s State Planning Commission analysis of the
Multidimensional Poverty Index (MPI), the headcount ratio declined from ~4.9% (2015–16) to ~1.6% (2019–
21), with the MPI value dropping from 0.020 to 0.006, evidences that deprivations in health, education, and
living standards have eased markedly. Nationally, NITI Aayog reports a broad MPI decline over the last
decade, providing a favourable macro backdrop for Tamil Nadu’s progress. Yet disparities and contestation
persist. The 10.5% internal quota for Vanniyars (within MBCs) enacted in 2021 was struck down by the
Supreme Court in 2022 for relying on outdated data, underscoring the need for current caste-wise evidence to
refine internal reservations without eroding legal sustainability. In short, Tamil Nadu’s 69% reservation
regime constitutionally shielded coexists with high higher-education access and rapidly declining
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multidimensional poverty. The next frontier is data-rich, intra-category calibration (using updated
caste/education/labour indicators) to ensure that the most historically excluded sub-groups within
BC/MBC/SC/ST blocks translate legal entitlements into equitable educational and economic mobility.
The Creamy Layer Debate in India: Concept and Controversies
The creamy layer principle emerged from the Indra Sawhney v. Union of India (1992) judgment, which capped
reservations at 50% and introduced economic exclusion for OBCs. However, applying the same logic to SCs
has been contested. Proponents argue it prevents the monopolization of benefits by affluent SCs, while critics
stress that caste discrimination operates independently of income. The National Commission for Scheduled
Castes (2021) opposed its extension, citing persistent untouchability practices, over 50,000 atrocity cases
against SCs were registered nationally in 2020 (NCRB). This demonstrates that social stigma persists despite
upward mobility, undermining the creamy layer argument. The creamy layer was evolved by the Supreme
Court in Indra Sawhney (1992), which upheld 27% OBC reservation but required the exclusion of the socially
advanced among OBCs and set a general 50% cap on quotas. The income ceiling, ₹1 lakh (1993), was later
revised up to ₹8 lakh (2015). At the Union level, reservations are 27% for OBCs, 15% for SCs and 7.5% for
STs in jobs and central educational institutions (total 49.5%). Demographically, SCs are ~16.6% and STs
~8.6% of India’s population (Census 2011). The Mandal Commission (1980) estimated OBCs at ~52% based
on 1931 data, highlighting under-representation. Prevents capture of benefits by relatively better-off SC
subgroups, improving reach to the most marginalized; aligns with equality principles used for OBCs. Recent
Supreme Court signals, in promotion cases, endorsed excluding the creamy layer among SC/ST for
promotions.
SC status is tied to untouchability-based stigma, not mere economic progress; imposing a creamy-layer test
risks diluting remedial justice. It may also introduce complex, contentious intra-SC stratification. Indra
Sawhney (1992) imposed a 50% ceiling on the creamy layer for OBCs, with some exceptions. Jarnail Singh v.
Lachhmi Narain Gupta (2018) removed the "quantifiable backwardness" requirement from M. Nagaraj for
SC/ST promotions, but held creamy-layer exclusion applies. Parties often support OBC creamy-layer
exclusion while differing on extending it to SCs; parallel moves focus on internal categorisation within SCs to
target benefits (e.g., Karnataka’s split of its 17% SC quota among sub-groups). Senior judicial voices recently
called applying creamy layer within SC/ST a “milestone,” reflecting an evolving consensus on targeting.
Evidence of persistent under-representation (despite 49.5% reservations) and population shares (SC 16.6%, ST
8.6%, OBC ~52% est.) fuels the debate: extend creamy-layer logic to sharpen targeting, or preserve group-
based remediation for communities facing entrenched caste stigma.
The Myth of the SC Creamy Layer: Structural Exclusion and Caste Hierarchy
Unlike OBCs, Scheduled Castes face entrenched untouchability, which economic growth alone cannot erase.
Studies by Indian Institute of Dalit Studies (2018) reveal that nearly 60% of Dalit graduates experience caste-
based job discrimination. In Tamil Nadu, upwardly mobile SC families continue to face exclusion in social and
matrimonial spheres, showing the endurance of caste prejudice. Even in urban areas, caste identity remains a
barrier, with SCs concentrated in low-paying occupations. The creamy layer concept, therefore, ignores the
layered reality of caste-based exclusion, where education and income offer limited protection against deeply
embedded caste hierarchies. Socio-economic mobility does not dissolve caste stigma because caste marks are
social, spatial, and institutional, encoded in names, networks, neighborhoods, and gatekeeping norms. Even
upwardly mobile Scheduled Castes (SCs) face targeted risks: the NCRB recorded 57,582 crimes against SCs in
2022, a 13.1% rise over 2021, evidence that status gains do not insulate from caste-motivated violence. In
education, access has widened but hierarchies persist. SC higher-education enrolment reached 66.23 lakh in
2021–22, yet SCs remain slightly under-represented relative to their population share; official AISHE data
show category shares around 15% of total enrolment versus ~16.6% of population. Meanwhile, representation
plummets at the top: RTI-based reporting shows multiple IIT departments with no SC/ST/OBC faculty, and
across elite institutions >80–90% of faculty posts are often held by “General” category scholars, indicating
glass-ceiling effects despite student-level inclusion.
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Employment evidence likewise shows continuing exclusion beyond income. Classic decomposition studies
estimate ~15% of the SC/ST wage gap arises from discrimination unexplained by human capital. A well-
known Delhi correspondence test finds no caste penalty in software callbacks but significant gaps in call-
center jobs, underscoring that bias reappear in customer-facing segments. Space and everyday life reproduce
stigma. An ICSSR-supported audit of the urban rental housing market in Delhi-NCR documented high
rejection rates for Dalit applicants; face-to-face audits recorded around 60% denial odds tied to caste/religion
markers, even for salaried, educated seekers. Independent urban studies confirm persistent residential
segregation by caste. Taken together, rising atrocity cases, elite-faculty under-representation, labor-market
penalties, and housing denials, empirical evidence shows that economic mobility does not erase caste. The “SC
creamy layer” thesis mistakes income for inclusion; structural exclusion endures through institutional
gatekeeping, spatial segregation, and status policing across education, employment, and public life.
Tamil Nadu’s Resistance to the Creamy Layer Concept
Tamil Nadu has consistently resisted the creamy layer principle for SCs, arguing that caste oppression is not
comparable to economic class differences. The State’s Justice Party and Dravidian movements emphasized
representation as a tool to dismantle caste barriers. As a result, Tamil Nadu provides 18% reservation for SCs
without a creamy layer cap. Evidence from the Tamil Nadu Policy Note on Higher Education (2022) shows
that SC enrollment in higher education rose to 26.4%, nearly proportional to their population. This success
demonstrates that reservations must remain caste-sensitive rather than income-sensitive to address structural
inequalities. Tamil Nadu has consistently resisted applying the creamy layer idea to Scheduled Castes (SCs),
insisting that reservation must protect all SC communities rather than exclude better-off sub-groups. The
state’s distinctive stance is rooted in policy and law: Tamil Nadu’s caste quota totals 69% (established via the
Tamil Nadu Backward Classes, SCs & STs Act, 1993) and the state successfully placed its Act in the Ninth
Schedule to shield it from judicial reversal. Two features explain this resistance. First, the Dravidian
movement, from Periyar’s social-reform politics through DMK/AIADMK state governance, centred social
justice and mass redistribution rather than narrow meritocratic exclusion, producing political pressure to keep
broad, universal reservations. This historical and ideological lineage is well documented in scholarly accounts
of the Dravidian model. Second, Tamil Nadu treats reservations as structural redress for entrenched caste
disadvantages across entire communities; officials worry that a creamy-layer rule (which filters out relatively
better-off households) would fragment solidarity and weaken access for many historically excluded sub-castes.
The state has actively taken legal and administrative steps (including committees to monitor
promotion/reservation impacts) to defend its approach.
By contrast, several other states have seen more active creamy-layer debates or sub-classification moves:
Andhra Pradesh and Karnataka have pursued sub-categorisation of SCs/STs and internal redistribution to
address intra-group inequalities, and national courts have entertained applying differential tests, making these
states focal points of contention. Commentators and legal analysts note growing national-level
judicial/legislative interest in carving exceptions that Tamil Nadu resists. In short, Tamil Nadu’s resistance
combines (a) a 69% universal-quota legacy, (b) Dravidian political ideology prioritizing broad social justice,
and (c) active policy/legal defence, while states like Andhra and Karnataka have been more open to sub-
classification/creamy-layer style reforms.
Socio-Economic Disparities among SCs/ STs, SC(A), BC and MBCs in Tamil Nadu
Despite progress, disparities persist within SCs themselves. For instance, the Arunthathiyars (7% of the SC
population) have historically lagged behind other SC sub-castes. Recognizing this, Tamil Nadu introduced a
3% sub-quota within SC reservations in 2009. A report by the State Adi Dravidar Welfare Department (2020)
showed that Arunthathiyar literacy rates (66.7%) were significantly lower than the overall SC average
(73.26%). Employment statistics also reveal concentration in low-paying, stigmatized work. While
reservations have improved representation, intra-caste inequalities challenge the notion of a uniform SC
community, underscoring the need for sub-classifications without adopting the creamy layer principle. Tamil
Nadu’s reservation landscape shows clear internal stratification, Scheduled Castes (SCs) form a substantial
minority in the state, but benefits of reservations and welfare are unevenly shared across SC sub-castes, and
between SC, ST, BC and MBC groups. The 2011/earlier Census records Tamil Nadu’s SC population as
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roughly 18–19% of the state (district tables/Census). The state’s reservation architecture attempts corrective
targeting, Tamil Nadu provides 15% for SCs plus an additional 3% specially for Arunthathiyar (SC-A),
amounting to 18% SC reservation, and an unusually high overall caste quota (widely reported at ~69%).
These measures recognise intra-SC disadvantage but have not eliminated skewed outcomes. Empirical and
NGO reports document the unequal take-up of benefits: Arunthathiyar and other most-marginal SC sub-castes
remain under-represented in public employment and higher-education seats relative to their population share
(reports find Arunthathiyars often receive <10% of reservation allocations meant proportionally for them).
This indicates capture of opportunities by relatively advantaged SC sub-groups.
Scholars and policy analysts warn that without finer targeting (sub-classification or calibrated sub-quotas)
reservation can reproduce intra-group inequality, while opponents fear sub-division could fragment Dalit unity
or dilute the universal principle of social justice. Recent debates therefore call for evidence-based
redistribution (using caste-disaggregated data on education, employment and poverty) to steer benefits toward
the most deprived without eroding anti-discrimination aims. Addressing these disparities requires balancing
equity and unity. Tamil Nadu’s experience shows that while broad-based quotas uplift marginalized
communities, internal hierarchies persist, leaving the poorest sub-castes like Arunthathiyars or certain ST
groups behind. Studies highlight that poverty incidence among SCs is still 32–34%, compared to 20% among
BCs and less than 15% among Forward Castes, reflecting continued socio-economic gaps. Unequal land
ownership, limited access to higher education, and wage discrimination exacerbate deprivation. Therefore,
reservation policies must be complemented with targeted socio-economic interventions, ensuring fair
distribution of benefits without weakening the foundational principle of social justice and collective
empowerment. In short, combine disaggregated monitoring, proportionate sub-quotas were justified, and
strengthened outreach (scholarships, placements, local representation) so reservation advances equity within
communities while upholding broader social-justice goals.
The Flawed Argument of the SC Creamy Layer: Towards Inclusive Development through Education,
Reservation, and Anti-Discrimination Measures
The Supreme Court’s application of a “creamy layer” argument to Scheduled Castes is empirically and
normatively weak. Poverty and educational deficits remain widespread among SC communities: the 2011
Census records the SC population at ~201 million with an overall literacy of 66.07%, below national averages.
Rural poverty estimates show over one-third of SC households remained below the poverty line in 2011–12
(about 33.8%), underscoring persistent material disadvantage. Crucially, multiple empirical studies and
commentators find that economic mobility does not erase caste-based exclusion: discrimination in housing,
social interactions, education and labour markets persists even for upwardly mobile Dalits, so wealth alone is a
poor proxy for vulnerability. Legal scholars and policy analysts have also noted that proposals to apply a
creamy-layer exclusion to SC/ST quotas lack robust caste-level data to identify “forward” subgroups, making
blunt income cutoffs likely to misclassify and exclude many who remain socially marginalized.
Policy pathway such as, preserve reservation as an anti-exclusion tool while improving targeting through sub-
classification only after a comprehensive, transparent caste census and microdata analysis; and Invest heavily
in educations such as bridge programmes, scholarships, quality improvements, because higher completion
rates are foundational to mobility, Census and MOSPI show persistent education gaps that demand remedial
action. Enforce anti-discrimination laws, expand affirmative outreach in hiring and schooling, and monitor
outcomes with disaggregated indicators (poverty, learning, employment) so policy responds to social, not just
economic, exclusion. Furthermore, inclusive development requires bridging structural inequities beyond
material metrics. While a narrow creamy layer lens assumes income erases stigma, field studies reveal that
Dalits with higher education or salaried jobs still face social ostracism, residential segregation, and hiring bias.
This indicates that caste hierarchies reproduce disadvantages across generations irrespective of individual
progress. Therefore, reforms must integrate social justice with economic growth: expanding digital literacy,
vocational training, and entrepreneurship among SC youth; enforcing workplace diversity; and sensitizing
institutions against implicit bias. Only through this holistic approach can reservations, education, and anti-
discrimination measures converge to dismantle entrenched caste barriers. In short, treating caste disadvantage
as reducible to income risks undoing constitutional commitments to substantive equality; evidence calls for
data-driven, multi-pronged remedies, education, reservation, and strict anti-discrimination enforcement.
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Castes Politics and Reservation Dynamics in Tamil Nadu: From Historical Marginalization to Emerging
Political Power
During the time of Kamaraj and M.G.R., reservation stood at 31% for Backward Classes (BC), 18% for
Scheduled Castes (SC), and 1% for Scheduled Tribes (ST). In 1989, Karunanidhi restructured the reservation
system by dividing the seats among 118 castes under BC and 110 castes under the newly formed Most
Backward Classes (MBC), allotting 30% to BC and 20% to MBC. Within MBC, priority was given to right-
wing communities like Denotified Tribes, Kallar, and Maravar. This decision was presented in the Assembly
without debate, but before it could be implemented, the government was dissolved. Later in 1991,
Karunanidhi’s plan was executed by Jayalalithaa with the support of Sasikala. Karunanidhi did not stop there.
In 2009, he further divided the Scheduled Castes by allocating 3% exclusively to the Arunthathiyars,
introducing a 200-point rotational system to prioritize them. However, communities such as Vettiyan,
Semman, Puthirai Vannan, who face even harsher conditions, were excluded. This arrangement largely
sidelined the Paraiyar community within the SC category. Since 1969, Paraiyars have borne the brunt of the
power politics of the ruling parties.
In the 2024 elections, the DMK alliance faced setbacks in Villupuram and Chidambaram, where the
community expressed its discontent. If AIADMK and BJP votes are combined, the DMK alliance would lose
12 crucial seats. In 2021, DMK secured 128 out of 234 seats, with nearly 60 from the northern districts,
strongholds of the Paraiyar population. The question now is whether the Paraiyars will determine the future
government. If they do, the political influence they once held before 1967 could see a revival. The Paraiyar
community holds a decisive role in shaping Tamil Nadu’s political future. Their unity and assertion can
challenge the dominance of major parties that have historically sidelined them through divisive reservation
policies. The lesson taught in Villupuram and Chidambaram is only the beginning. If their political strength is
consolidated, alliances and vote banks will shift dramatically, especially in the northern districts. For decades,
the voice of the Paraiyar has been muted under the shadow of larger caste interests, but the current political
climate presents an opportunity for resurgence, reclaiming leadership reminiscent of the pre-1967 era.
According to the data, only 0.5% of Scheduled Caste (SC) households in India earn more than ₹66,000 per
month, while a vast majority, 83.55%, survive on less than ₹5,000 per month. Another 11.74% fall in the
₹5,000–10,000 income bracket, and merely 4.67% earn above ₹10,000 monthly. If we apply the OBC and
EWS income criteria of ₹66,000 per month, virtually the entire SC population, except for that 0.5%, would
qualify. This raises a critical question: on what basis did the judiciary conclude that a so-called “creamy layer”
within the SCs is cornering the benefits of reservation.
The idea of a “creamy layer” among Scheduled Castes (SCs) is deeply contested when examined against
income statistics. Data shows that only 0.5% of SC households in India earn more than ₹66,000 per month, the
income threshold applied for OBC and EWS categories. In contrast, a staggering 83.55% of SC households
survive on less than ₹5,000 per month, while 11.74% earn between ₹5,000 and ₹10,000, and only 4.67% report
a monthly income above ₹10,000. These figures demonstrate that the overwhelming majority of SC families
continue to live under severe poverty and socio-economic marginalization. Even among the small upwardly
mobile sections, caste-based discrimination persists in education, employment, housing, and social
interactions. Studies by the National Sample Survey (NSS) and the India Human Development Survey (IHDS)
reveal that SCs, regardless of income, face barriers in accessing equal opportunities. Landlessness, low literacy
levels, and high dependence on casual labor further reflect structural disadvantages. Given that only a
negligible proportion of SC households cross the ₹66,000 threshold, it is questionable how judges concluded
that a so-called creamy layer is monopolizing reservation benefits, when the data clearly shows that economic
upliftment has barely touched this community, and social exclusion remains entrenched.
Constitutional Provisions Relating to the Reservation System in India
The reservation system in India is rooted in the Constitution of India, aimed at ensuring social justice and
equality for historically marginalized communities such as the Scheduled Castes (SCs), Scheduled Tribes
(STs), and Other Backward Classes (OBCs). Articles 15(4) and 15(5) empower the state to make special
provisions for the advancement of socially and educationally backward classes in educational institutions.
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Article 16(4) enables reservation in public employment, while Article 46 under the Directive Principles directs
the state to promote the educational and economic interests of weaker sections. Additionally, Articles 330 and
332 provide political reservations in the Lok Sabha and State Assemblies. The landmark First Constitutional
Amendment (1951) laid the foundation for educational reservations, while the 77th Amendment (1995)
introduced reservation in promotions for SCs and STs (Article 16(4A)). The 81st Amendment (2000) allowed
the carry-forward of unfilled reserved vacancies, and the 93rd Amendment (2005) provided reservation in
private unaided educational institutions (except minority institutions). The 103rd Amendment (2019)
introduced 10% reservation for Economically Weaker Sections (EWS) in education and jobs, extending the
principle beyond caste.
Statistically, according to the 2011 Census, SCs constitute 16.6%, STs 8.6%, and OBCs are estimated at 41%
of India’s population (as per the Mandal Commission and NSSO data). Currently, the reservation stands at
15% for SCs, 7.5% for STs, 27% for OBCs, and 10% for EWS, totaling 59.5% at the central level, though
states like Tamil Nadu have extended it to 69% under special provisions. Despite criticisms of perpetuating
caste identities, reservation has significantly improved representation. For instance, SC/ST literacy rates rose
from 21.38% (1961) to 66.1% (2011), indicating progress through affirmative action. Thus, constitutional
provisions on reservation continue to play a pivotal role in balancing historical injustice with equitable
opportunities in modern India. While reservations have expanded access, challenges of unequal intra-group
benefits persist, as dominant sub-castes within SCs, STs, and OBCs often secure a disproportionate share. The
Sachar Committee Report (2006) and NSSO surveys reveal that many Dalit and Adivasi households still face
poverty, with over 40% of SCs and 45% of STs below the poverty line in rural areas. Furthermore, in higher
education, despite quotas, SC enrollment remains at 14.7% and ST at 5.6% (AISHE 2020-21), still below their
population share. These disparities highlight that constitutional provisions, though vital, require
complementary policies for equitable and inclusive social justice.
Articles 15(4) and 15(5) empower the state to provide reservations in educational institutions. As per AISHE
2020-21, SC enrollment in higher education is 14.7%, STs at 5.6%, and OBCs at 36.3%, showing progress but
still below their population share (SCs 16.6%, STs 8.6%). The 93rd Amendment (2005) also extended
reservations to private unaided institutions (except minorities). Under Article 16(4), SCs, STs, and OBCs
receive reservations in public employment. The 77th Amendment (1995) added reservation in promotions for
SC/STs. As per Department of Personnel and Training (2021), SCs hold 17.5% of central government jobs and
STs 7.6%, roughly matching their population shares, though representation in higher posts remains low.
Articles 330 and 332 ensure political representation by reserving 84 Lok Sabha seats for SCs and 47 for STs
(2019). In State Assemblies, over 1,000 constituencies are reserved for SC/ST candidates, ensuring their voices
in governance.
Contemporary Relevance of the Reservation System in Modern India and Tamil Nadu
The reservation (quota) system remains a central instrument of social justice in modern India and Tamil Nadu:
it corrects historic exclusion, expands access to education and public employment, and shapes political
representation, even as debates about its scope, targeting and duration intensify. At the national level the 2011
census and related sources put Scheduled Castes (SCs) at roughly 16–17% and Scheduled Tribes (STs) near 8–
9% of the population; the central government’s statutory quotas (for direct recruitment/on-campus admissions)
currently approximate 15% (SC), 7.5% (ST) and 27% (OBC) in many central contexts. Tamil Nadu is an
outlier in policy design and size of reservation: the state’s consolidated reservation today is commonly
reported at about 69% (with allocations historically split across Backward Classes, Most Backward Classes,
SCs and STs), a level well above the 50% ceiling that dominates Supreme Court jurisprudence and which has
generated continuing litigation and political debate.
Contemporary relevance, education and employment. Government data and academic studies show persistent
gaps in higher-education participation and labour-market outcomes for SC/ST and many OBC subgroups;
reservation remains a primary policy lever to raise enrolment, secure government jobs and build representative
institutions, especially where private expansion has unevenly benefited privileged groups. The announcement
to include caste details in forthcoming census rounds has renewed demands for recalibration of quotas (state
demands for higher shares, internal sub-quotas, and reclassification). That political fallout makes reservation
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both a governance necessity for inclusion and a politically charged instrument that must balance fairness, data
accuracy and constitutional limits. Reservation in India and Tamil Nadu continues to be highly relevant: it
reduces measured exclusion and improves representation, but it also requires up-to-date data, finer targeting (to
avoid leakages/duplication) and complementary investments (quality schooling, skill training) so quotas
translate into sustained socio-economic mobility.
Tamil Nadu’s Unique Stand on Creamy Layer: A Contrast with National and Other State Models
Tamil Nadu’s approach to the “creamy layer” concept is distinctive because the state treats reservation
primarily as a caste-and-social-backwardness measure rather than an economic one, and it has preserved a
much larger aggregate quota than the national norm. Tamil Nadu continues to operate an overall reservation of
69% (established through state Acts and protected by successive legal and political measures), whereas the
Supreme Court’s Indra Sawhney (Mandal) line has generally limited reservations to 50% and required
exclusion of the “creamy layer” within OBCs at the central level. At the national level the central OBC quota
is 27%, and the Mandal framework explicitly applies the “creamy layer” exclusion for OBC beneficiaries, i.e.,
the relatively better-off among OBCs are removed from quota benefits to target the socially and educationally
backward. Tamil Nadu, however, argues that caste-based social disadvantage cannot be captured solely by
income cutoffs and that broad caste-based protection remains necessary in the state’s socio-political context.
Legal and political tensions follow. The Supreme Court has repeatedly upheld the 50% ceiling in many
contexts, creating friction with Tamil Nadu’s higher ceiling; courts have also scrutinized state laws that expand
quotas without up-to-date empirical data (the 2021 Special Reservation Act was struck down in litigation over
lack of quantifiable backing). Meanwhile, the Centre has signalled it will not introduce a “creamy layer” rule
for SC/ST reservations, even as some judges have suggested mechanisms to identify and exclude advantaged
sub-groups within SC/STs. These developments mean the creamy-layer debate now sits at the intersection of
law, demography, and politics. Tamil Nadu’s model is distinctive because (1) it preserves a 69% aggregate
quota rooted in caste categories rather than income tests, (2) it resists the uniform application of creamy-layer
income cutoffs used for OBC policy at the centre, and (3) ongoing litigation and national policy signals keep
the issue contested, with implications for how targeted and constitutional affirmative action should be. In short,
Tamil Nadu’s model prioritizes caste-based social backwardness and broad protective quotas; without recent
caste-wise data the state faces legal vulnerability under Supreme Court tests (50% ceiling, evidence-based
quota expansion). A state caste survey/census is the most likely legal remedy to strengthen Tamil Nadu’s
defence.
Strengthening Reservation Discourse in Tamil Nadu through Social Justice Theories
Tamil Nadu’s reservation policies, which currently stand at 69% for SC, ST, BC, MBC, and DNC categories,
have long been framed as instruments of social justice. A deeper theoretical engagement with thinkers like
B.R. Ambedkar, John Rawls, Will Kymlicka, and Nancy Fraser can enrich the understanding of their ethical
and political foundations. Ambedkar argued that caste is not merely a division of labor but a division of
laborers, necessitating structural interventions. His principle of “liberty, equality, fraternity” underlines Tamil
Nadu’s commitment to dismantling caste hierarchies through affirmative action. Statistical evidence supports
these gains: Gross Enrolment Ratio (GER) in higher education for SCs in Tamil Nadu was 28.6% in 2020–21,
significantly higher than the national average of 23.4% (AISHE, 2021), reflecting the impact of sustained
reservations.
Rawls’ difference principle asserts that inequalities are justifiable only if they benefit the least advantaged.
Tamil Nadu’s expansion of reservations beyond the 50% ceiling recognized by the Supreme Court reflects a
Rawlsian attempt to prioritize equity over formal equality. Meanwhile, Kymlicka’s defense of group-
differentiated rights validates Tamil Nadu’s recognition of historically disadvantaged castes and communities
as requiring targeted support for genuine democratic participation. Nancy Fraser’s concept of redistribution
and recognition is particularly relevant. Reservations in Tamil Nadu not only redistribute opportunities in
education and employment but also provide symbolic recognition of marginalized identities, countering stigma
and exclusion. Yet challenges remain: reports suggest that nearly 30% of Dalit households in Tamil Nadu still
lack access to safe sanitation, reflecting persistent socio-economic inequality despite reservation gains (NSSO,
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2019). Thus, grounding Tamil Nadu’s reservation discourse in broader social justice theories highlights both
its achievements and its unfinished agenda, moving beyond access towards dignity, equality, and structural
transformation. In short, while Tamil Nadu’s reservation policies resonate with Ambedkar’s radical call for
caste annihilation and Fraser’s dual demand for redistribution and recognition, they face critical challenges.
The creamy layer debate within OBCs, uneven intra-caste benefits, and persisting socio-economic deprivation
indicate that redistributive justice is not fully achieved. A Rawlsian perspective would argue for refining
targeting mechanisms to ensure benefits reach the most disadvantaged. Similarly, Kymlicka’s emphasis on
multicultural citizenship underscores the need to combine reservations with skill development and
empowerment programs. Strengthening caste-disaggregated data collection and integrating welfare with
dignity-based policies remain vital for inclusive justice.
CONCLUSION
The debate on the SC creamy layer often overlooks the reality that social stigma persists irrespective of income
levels. Evidence from Tamil Nadu shows that while education and employment indicators for SCs have
improved, socio-economic disparities and caste-based exclusion remain. To ensure equitable development,
policy must prioritize strengthening sub-quotas, enhancing quality education, promoting entrepreneurship, and
enforcing anti-discrimination laws. National Crime Records Bureau (2021) data on caste atrocities, 13,147
cases in Tamil Nadu alone since 2015, proves that caste is far from irrelevant. Thus, revisiting reservation
requires nuance: targeting disparities while rejecting the flawed myth of the SC creamy layer. The reservation
system in Tamil Nadu exemplifies a longstanding commitment to social justice, aiming to dismantle caste
hierarchies and promote equitable access to education, employment, and political representation. With a
notably high reservation quota of around 69%, Tamil Nadu has prioritized broad, community-based
affirmative action over the application of the “creamy layer” principle, which seeks to exclude socio-
economically advanced sub-groups within marginalized communities. This stance is rooted in the state's
historical and ideological focus on caste-based redress, emphasizing that caste discrimination persists
regardless of economic mobility.
Empirical evidence highlights ongoing disparities: despite improved literacy and reduced poverty, SCs in
Tamil Nadu continue to face social exclusion, lower income levels, and under-representation in elite
institutions and high-level jobs; caste-based atrocities and social biases remain entrenched. The “creamy layer”
debate, which seeks to refine reservation targeting by excluding the relatively affluent, is contentious because
caste-based discrimination is not solely economic, it is social, spatial, and institutional. Tamil Nadu’s
resistance to this concept underscores its belief that reservation must protect entire communities facing
systemic oppression, not just those who are economically better-off. Internally, disparities among SC sub-
castes like Arunthathiyars further complicate matters, calling for finer classification and targeted interventions
rather than blanket exclusion. Overall, while Tamil Nadu’s expansive reservation policy has advanced
representation and reduced poverty, persistent intra-community inequalities and caste prejudices demand
nuanced, data-driven policies that balance social justice with effective targeting. The core challenge remains
ensuring that affirmative action translates into meaningful socio-economic mobility, while safeguarding the
principle of caste-based redress against superficial economic criteria.
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