"It is an injustice to treat unequals as equals, just as it is an injustice to treat equals as unequals."-- Aristotle[1]

Dr BR Ambedkar highlighted how the British government had deliberately intended to keep education "as the preserve of higher classes" in the Bombay Presidency by maintaining a paltry number of schools and colleges. Amidst the demands to increase the number of educational institutions and enhance the ambit of education to the poor as well, Ambedkar cited from the 'Report of the Board of Education of the Bombay Presidency of 1850–51'[2] and pointed to a situation which the British government and the higher classes of western India earnestly wanted to avoid: "If the children of the poor are admitted freely to government Institutions, what is there to prevent all the despised castes - the Dheds, Mahars etc - from flocking in numbers to their walls?"

The Mandal Commission's recommendations in 1990[3], aimed at offering chances to historically disadvantaged groups, laid the groundwork for the notion of reservations for Economically Weaker Sections (EWS) in India. The demand for EWS reservations grew, resulting in the passing of the 103rd Constitutional Amendment Act in 2019[4], which included a 10% quota for economically disadvantaged citizens in general.

The demands for EWS reservations include equal access to education and employment, inclusivity for economically disadvantaged individuals, the promotion of socioeconomic mobility, and a reduction in economic inequality. The constitutional validity of EWS reservations has been upheld by the Supreme Court of India, as long as they do not exceed the 50% cap on reservations and are consistent with principles of social justice and equal opportunity. These reservations aim to address economic disparities and create a more inclusive society.

Significance of the study
This article presents in-depth study on EWS, its origin, demands and its constitutional validity.

This research attempts to give extensive information of the issue to the academics and has attempted to explain every element feasible in order to make it understandable.

This study intends to offer students with understanding of a less-discussed issue. Illustrations have also been presented to aid comprehension.

Methodology
This research work for the project has been carried with help of secondary resources. The data or information for the said topic has been cited whenever and wherever required, and due credits are given to the original content writer. There is no use of the primary method for the collection of data and is strictly limited to secondary resources. Both direct and indirect methods have been used by the researcher to gather the information

Adding to this, several examples are provided, and the work done by the eminent authorities, researchers, authors of the books, and conclusions have been taken into consideration.

Scope and Limitations of the Study/Project Work
Despite the limitations of time and money at the disposal of the researcher, it has been decided to confine this study to the selected method of finding resources through several sites, which are provided in the bibliography.

This study is self-exploratory in nature and therefore multistage stratified sampling techniques have been used for the collection of the data.

Introduction
Reservation is an affirmative action system in India that provides historically disadvantaged communities with representation in education, jobs, government initiatives, scholarships, and politics. Based on provisions in the Indian Constitution, it allows the Union Government and the States and Territories of India to set reserved quotas or seats, at a specific percentage, in Education Admissions, Employments, Political Bodies, Promotions, and so on, for "socially and educationally backward citizens."

The reservation policy has been in place in India for a long time. Its roots can be traced back to ancient times when the practise of 'untouchability,' the caste system, and the Varna system were prevalent in society. In ancient times, Hindu society was divided into Varna, Jatis, or classes, which were as follows in descending order of social hierarchy: Brahmans, Kshatriyas, Vaisyas, and Shudras. There was another class of people, or rather no class of people, known as "untouchables" or "avarna," which means "untouchables" or "avarna."

These untouchables were deemed unfit for society and were thus excluded from the social structure.[5]

The caste system that existed at the time played a significant role in the development of India's reservation policy. Because of the frequent atrocities committed against the particular class of people, the concept of granting reservations to them first emerged. The implementation of the reservation policy in India was motivated by the need to provide them with equal access to opportunities and social standing, as well as to socially elevate them and bring them on par with other social groups and, moreover, to promote growth among the lower strata of society.

Analysis
Economically Weaker Section (EWS) in India is a subcategory of people having an annual family income less than ₹8 lakh (US$10,000) and who do not belong to any category such as SC/ST/OBC across India, nor to MBC in Tamil Nadu. A candidate who does not fall under SC/ST/OBC and fulfils the EWS economic criteria are to be part of the EWS category[6].[7]

The very form of the EWS quota excludes castes and tribes enumerated under the categories of SC, ST, and OBC, thus effectively excluding around two-thirds of India's population from availing it. As has been pointed out by a number of commentators, EWS is, for all intents and purposes, a quota for the social minority of the higher castes, which, as a class, is statistically deemed to be the richest in India. [8]By rendering poverty among the higher castes as deserving of the intervention of reservation or affirmative action, the government and the judiciary have effectively created two different forms of dealing with poverty in India.

The distinction between the deserving and the undeserving poor can be illustrated through some examples from the ancient lawbook of the Manusmriti or The Law Code of Manu. For example, verse 10.129 reads, "Even a capable Sudra must not accumulate wealth; for when a Sudra becomes wealthy, he harasses Brahmins."[9]


History:
Reservation in India dates to the late 19th century. The British had set up the Education Commission in 1880, also Hunter Commission[10] headed by Sir Willian Wilson Hunter. Reformer Jyotirao Phule petitioned the Commission that the British should introduce reservation for the historically marginalised groups.

In 1902, Kolhapur ruler Chhatrapati Shahu implemented 50 per cent reservation for the backward classes, which mostly meant non-Brahmins at the time. Other princely states too took the lead in affirmative action.[11]

"Some of these princely states were progressive and eager to modernise through the promotion of education and industry; and by maintaining unity among their own people. Mysore in south India and Baroda and Kolhapur in western India took considerable interest in the awakening and advancement of the minorities and deprived sections of society," notes Bhagwan Das in Economic and Political Weekly

Mandal Commission:
The Mandal Commission or the Socially and Educationally Backward Classes Commission (SEBC), was established in India in 1979 by the Janata Party government under Prime Minister Morarji Desai [12]with a mandate to "identify the socially or educationally backward classes" of India[13]. It was headed by B. P. Mandal, an Indian parliamentarian, to consider the question of reservations for people to address caste discrimination, and used eleven social, economic, and educational indicators to determine backwardness[14].

In 1980, based on its rationale that OBCs ("Other backward classes") identified on the basis of caste, social, economic indicators made up 52% of India's population, the commission's report recommended that members of Other Backward Classes (OBC) be granted reservations to 27% of jobs under the Central government and public sector undertakings, thus making the total number of reservations for SC, ST and OBC to 49.5%.[15]

Though the report had been completed in 1980, the V. P. Singh government declared its intent to implement the report in August 1990, leading to widespread student protests[16]. As per the Constitution of India, Article 15 (4) states, " Nothing in this Article or in clause(2) of Article 29 shall prevent the State from making any provision for the advancement of any socially or educationally backward classes of citizens or for Scheduled Castes and Scheduled tribes".

The Mandal Commission had therefore created a report using the data of the 1931 census, the last caste-aware census, extrapolated with some sample studies. V. P. Singh was accused of using the Mandal Report which was ignored by the Janata government. It was a social revolution and affirmative action. All of a sudden almost 75% of Indian population got preferential treatment in educational admissions and Govt employment. Earlier 25% population of India which is SC ST was covered and now more than 50% of Other Backward Class came under reservation[17]. The youth went for massive protest in large numbers in the nation's campuses, resulting in many self-immolations by students.[18]

Indira Sawney challenged the Mandal Commission and government decision to implement it in the Supreme Court in front of a nine Judge bench. After hearing both sides the bench passed the Act with a provision that maximum reservation can be 50% of the educational seats or job vacancies and creamy layer of income will be applicable. Presently the creamy layer limit is Family income of ₹8 lakhs per year. It was implemented in 1992[19].

Even before the Mandal Commission some Indian states, like Tamil Nadu, Maharashtra, already had high reservations for socially downtrodden and economically poor people

On 7 January 2019, Union Council of Ministers approved a 10% reservation in government jobs and educational institutions for the Economically Weaker Section (EWS) in the unreserved category. The cabinet decided that this would be over and above the existing 50% reservation for SC/ST/OBC categories.

On 8 January 2019, The Constitution (One Hundred and Third amendment) Bill, 2019 was tabled in the Lok Sabha, [20]the lower house of the Parliament of India and it was passed on the same day. The bill was passed by the upper house Rajya Sabha on 9 January. President Ram Nath Kovind gave assent to the bill on 12 January 2019, and a gazette was released on the bill, which turned it into law. Coming into force on 14 January 2019, the One Hundred and Third Amendment of the Constitution of India amended articles 15(6) and 16(6) of the Constitution of India to permit 10% reservations to the EWS category. A number of state cabinets approved the law and announced their intention to implement the 10% EWS reservations.

On 10 January 2019, Youth For Equality[21], an NGO that opposes caste-based policies, challenged the proposed amendment at the Supreme Court of India on grounds that it breaches the 50% reservations ceiling set by the same court; the group said it fully supports EWS reservations but wants this to be done by converting the existing 27% OBC quota into an economic means-tested non-caste-based quota instead, thus staying within the 50% cap set by the apex court.

Conversely, leaders of Backward Classes welfare groups also approached the Supreme Court, opposing reservations for EWS groups altogether, arguing that EWS groups did not meet the reservations criteria that the same court had specified in an earlier case.

On 25 January 2019, the Supreme Court refused to stay the 10% reservation given to GEN-EWS category in government jobs and educational institutions. On 6 August 2020, the court decided that a 5-member bench would hear the case.

On 7 November 2022, Supreme Court of India by a 3:2 verdict in Janhit Abhiyan vs Union Of India Writ Petition (Civil) No(S). 55 of 2019[22], upheld the validity of the 103rd constitutional amendment carried out to provide legal sanction carve out 10% reservation for the economically weaker sections from unreserved classes for admission in educational institutions and government jobs and held that the 50% cap on quota is not inviolable and affirmative action on economic basis may go a long way in eradicating caste-based reservation. This constitutional amendment pushed the total reservation to 59.50% in central institutions.

If honourable Leaders know this stance that we must protect two stuffs, namely the concept of equal opportunities and, at the same moment, meet the demands of groups which have not previously been represented in the State, then it is sure they will agree that, unless you are using such a qualifying sentence as backward" the reservation exception will eventually eat. Nothing remains of the law."

In M.R. Balaji v. State of Mysore[23], the Supreme Court extended this reasoning to remove the 68% reservation made pursuant to Article 15(4) for admission to medical and engineering schools in the (then) State of Mysore and ruled that the reservation should not in any event exceed 50%.

As per this perspective, Articles 15(4) and 16(4), which provide for reservations in education and public employment, act as "exceptions" to the equality and non-discrimination regulations of Articles 15(1) and 16(1), thereby infringing' 50 per roof' leads to reverse discrimination. In N.M Thomas[24], from that point of perspective, the Supreme Court created a deviation.

It held that Article 16(1), as a facet of the equality doctrine, allows a fair classification of all individuals likewise located with regard to the law just as Article 14 does. Article 16(1) itself allows reservations and preferential treatment without Article 16(4). Seen in this manner, Article 16(4) is not the exception to Article 16(1), but an "emphatic re-establishment" and aims to create explicit what Article 16(1) already implies. Additional support for this line of reasoning is provided through the use of non-discrimination clause:
"Nothing in this Article shall stop the State from expressing its intensions in a most explicit manner" in Article 16(4), which is a legislative instrument, that the authority conferred therein is not in any manner restricted by the primary clause, i.e., Article 16(1), however, falls outside.

Therefore Article 16(1) states integrated vision of equality comprising both formal equality and significant equality ideals within it. Articles 15(1) and 15(4) apply the same logic." This is not an intellectual quibble, but a very practical matter. The "50 percent ceiling" logic of M.R. Balaji for reservations was based on the claim that the exemption cannot be extended to crush the rule. If Article 16(4) does not constitute the exception to Article 16(1), otherwise this reasoning is no longer valid and there's nothing to stop the State from violating the' 50% ceiling' for reservations only if the overall population of the underrepresented classes themselves is less than 50%, which is not the case in India.

In K.C. Vasant Kumar v. State of Karnataka[25], two learned judges of the Supreme Court came to the exact opposite findings on this issue-one held that N.M. Thomas (1975) undermines the rule of "50% ceiling" in M.R. Balaji, while another said it didn't.

Reservation in the Constitution of India
The reservation is mentioned in Article 46 of Part IV of the Constitution of India, which contains Directive Principles of State Policy (DPSPs). These provisions are non-enforceable but are meant to serve as guiding principles for lawmakers. Several of the provisions mentioned here, including reservations, have been made into laws over the years.

"Since 1950, the successive governments at the Centre and in the states have made several laws and formulated various programmes for implementing the Directive Principles of State Policies," notes M Laxmikanth in his book Indian Polity,[26] and lists some examples like the establishment of Planning Commission, laws for minimum wages and equal treatment of workers, maternity benefit laws, legal aid provisions, etc. [27]

Article 46 states, "The state shall promote with special care the educational and economic interests of the weaker sections of the people, and, in particular, of the Scheduled Castes and the Scheduled Tribes, and shall protect them from social injustice and all forms of exploitation."

The principle of Article 46 is reflected in Articles 15 and 16 of the Constitution which actually provide for the provisions of reservations in education and employment.

Moreover, Articles 330 and 332 of the Constitution reserve seats for SCs and STs in Lok Sabha and state assemblies.

However, the provisions in Article 15 were only added in 1951 through a constitutional amendment after the Supreme Court judgement nullified state reservations. [28]

The EWS reservation judgement, 2022[29]
Following the Narendra Modi government's introduction of EWS reservation in 2019, a number of petitions were filed. The Supreme Court decided on those petitions on November 7, ruling that the EWS reservation was constitutional.

There were three main questions in front of the Supreme Court in the EWS reservation case:

• Did the EWS reservation violate the Indra Sawhney judgement as it crosses the 50 per cent cap?
• Can economic status be the sole criteria of reservation?
• Can SC/ST/OBCs be excluded from the EWS reservation?

The first two questions are related to the Indra Sawhney decision.

In their majority decision, the three justices responded yes to these questions, while the two dissenting judges said no.

The majority decision concluded that affirmative action applies to all groups of backward persons, not only those who are socially and educationally behind.

"It is an instrument not only for inclusion of socially and educationally backward classes to the mainstream of society but, also for inclusion of any class or section so disadvantaged as to be answering the description of a weaker section. In this background, reservation structured singularly on economic criteria does not violate any essential feature of the Constitution of India and does not cause any damage to the basic structure of the Constitution of India," said Justice Dinesh Maheshwari in his majority judgement.

The majority judgement further said the 50 per cent ceiling is not inflexible and the 50 per cent ceiling applies only to reservation to socially and educationally backward classes, not to any other kind of reservation. Therefore, economically weaker sections —since they are a separate class— can have reservation outside of the 50 per cent ceiling, according to the Supreme Court.

The dissenting judgement, authored by Justice Ravindra Bhat, however, held the EWS reservation unconstitutional as it excludes SCs/STs/OBCs —with the reasoning that they enjoy another type of reservation— and that it breaches the 50 per cent reservation ceiling set in previous judgements. The dissenting judges were in principle okay with reservation on economic grounds.

Eligibility Criteria for the Economically Weaker Section (EWS)[30]
A 10% reservation in government jobs and educational institutes for the economically weaker section or EWS of the general category was approved by the union council of India in the year 2019. This reservation was decided to be over and above the 50% reservation that is mandatory for the ST/SC/OBC categories, so it ensures that these existing reservations are not affected by the reservation under the economically weaker section or EWS.

If you are an aspiring government job seeker or a student aspiring for admission in your dream institute, who happens to fall in the general category, you can enjoy this 10% reservation under the economically weaker section or EWS, provided you meet the eligibility criteria, which is as follows:

• You must fall under the general category which means you cannot belong to the SC/ST/OBC categories who already have reservations and the MBC category in case of Tamil Nadu.
• Your annual family income should be below 8 lakh rupees. An annual income of above 8 lakhs cannot be considered as economically weak and hence cannot fall under the economically weaker section (EWS).
• If your family owns any agricultural land, it should be less than 5 acres.
• If you or your family owns a flat, the area of the flat should be less than 1000 sq. Ft.

Is even 10% even valid?
The Report of the National Backward Classes Commission states forward Hindu caste and communities (which includes Brahmins, Bhumihars, Rajputs, Marathas, Jats, Vaishyas-Bania, Kayasthas and other forward Hindu castes) constitute 17.58% of the population[31]. In addition to these 17.58%, Buddhist (0.67%) and Jains (0.47%) are also not covered under any scheme of reservations.

This data has been recently used by the Supreme Court in deciding the civil appellate/original jurisdiction case Jaishri Laxmanrao Patil v. Chief Minister (also called Maratha Reservation case).[32] Based on the calculation of above data, it can be estimated that the total population outside the purview of reservation benefit in India is not more than 20%. For 20% socially and educationally forward population, the Government has reserved 10% seats in government jobs and education institutions with over-inclusive income brackets.

Though 50% has been set as the maximum limit for caste-based reservation, but this ceiling can be crossed in extraordinary circumstances[33]. Unfortunately, the Government is treating the underline situation as extraordinary in order to validate the breaching of 50% reservation ceiling while implementing 10% EWS reservation. Before delving into the discussion of whether the present matter falls within the ambit of an extraordinary situation, it is necessary to understand what comes under an extraordinary situation. Indra Sawhney case [34]has given illustration regarding certain extraordinary situation in para 810 of the said judgment:

810. … It might happen that in far-flung and remote areas the population inhabiting those areas might, on account of their being out of the mainstream of national life and in view of conditions peculiar to and characteristical to them, need to be treated in a different way, some relaxation in this strict rule may become imperative. In doing so, extreme caution is to be exercised and a special case made out.

The Supreme Court in para 475 of Maratha Reservation case [35]agreed that the expression "in far-flung and remote areas" incorporates geographical test and "the population inhabiting those areas might, on account of their being out of the mainstream of national life and in view of conditions peculiar to and characteristical to them" incorporates social test. In the same paragraph of the abovementioned case, the Supreme Court held that:

475 … one of the social conditions in para 810 (of Indra Sawhney case[36]) is that (not) being within the mainstream of national life, the case of Maratha does not satisfy the extraordinary situations as indicated in para 810 of Indra Sawhney[37], as the Marathas are in the mainstream of the national life….[38]

The above discussion makes it clear that due to over-inclusive nature of EWS definition, people from mainstream of national life are also covered for the benefit of reservation and therefore, the present case does not quench the extraordinary situations as specified in Indra Sawhney judgment[39]. Overstepping the 50% reservation maximum cap without there being any instance of extraordinary circumstances clearly flouts Articles 14 and 16 of the Constitution, which makes the enactment ultra vires. [40]

Under this background, it would not be wrong to conclude that the EWS reservation scheme criteria have been implemented without taking due consideration of gross domestic product (GDP)/per capita income, inter-State economical differences, rural urban purchasing power and other various data. This is a blatant manifestation of political moves in the guise of policy implementation with a lack of up-to-date and quantifiable data. In the line of a series of recent judgments, the Supreme Court and High Courts [41]have called attention to the significance of quantifiable data as a mandatory prerequisite for the reservation scheme in education and employment.

In Jaishri Laxmanrao Patil v. Chief Minister[42], the Supreme Court reiterated the observation held in M. Nagaraj v. Union of India [43]that if they are making provisions related to reservations, the State has to collect quantifiable data showing backwardness of the class and inadequacy of representation.

The Supreme Court in Maratha Reservation case [44]has struck down the reservation policy for Maratha as the Government could not back up the reservation policy with appropriate, adequate and quantifiable data. Same might be the fate of EWS Reservation policy, if the authority concerned could not come up with the necessary modification in tuned with appropriate and quantifiable data.

Conclusion
Economically Weaker Sections (EWS) reservations in India have emerged as a crucial policy tool to address economic disparities and promote inclusivity in education and employment opportunities. Originating from the recommendations of the Mandal Commission in 1990, which focused on social and educational backwardness, the concept of reservations for economically disadvantaged individuals from the general category gained momentum in recent years.

The passage of the 103rd Constitutional Amendment Act in 2019 ushered in a 10% quota for EWS, providing a legal framework for their inclusion in the reservation system. The demands for EWS reservations centre on the principles of equal opportunity, inclusivity, socioeconomic mobility, and the reduction of economic inequality. These reservations aim to level the playing field for economically disadvantaged citizens and ensure that they have access to quality education and job opportunities.

The constitutional validity of EWS reservations has been upheld by the Supreme Court of India, with the caveat that they do not breach the 50% cap on reservations and remain consistent with principles of social justice and equal opportunity. In this way, EWS reservations represent a significant step towards a more equitable and inclusive society, where economic disadvantage is recognized as a valid criterion for affirmative action.

As India continues to grapple with the complex issues of social and economic inequality, EWS reservations remain a topic of debate and discussion. Their implementation and impact on society will continue to be closely monitored, as they play a vital role in shaping India's future as an inclusive and just nation

End Notes:

1. The varieties of fairness - Ethics of AI. (n.d.). https://ethics-of-ai.mooc.fi/chapter-6/2-the-varieties-of-fairness
2. https://www.mea.gov.in/Images/attach/amb/Volume_12.pdf
3. Wikipedia contributors. (2023). Mandal Commission protests of 1990. Wikipedia. https://en.wikipedia.org/wiki/Mandal_Commission_protests_of_1990
4. Timesofindia.Com. (2022, November 7). Explained: What is the 103rd Constitution amendment upheld by SC. The Times of India. https://timesofindia.indiatimes.com/india/explained-what-is-the-103rd-constitution-amendment-upheld-by-sc/articleshow/95358575.cms
5. Critical Analysis of Reservation Policy In India. (n.d.). https://www.legalserviceindia.com/legal/article-5796-critical-analysis-of-reservation-policy-in-india.html
6. India Today. (2019, July 2). SC refuses to stay decision to grant reservation to EWS category. https://www.indiatoday.in/education-today/news/story/sc-refuses-to-stay-decision-to-grant-reservation-to-ews-category-1559725-2019-07-01
7. George, A. A. (2022). EWS Reservation Eligibility – Know the Criteria to apply for the 10% Economically Weaker Section Quota Seats. ClearIAS. https://www.clearias.com/ews-reservation-eligibility/
8. Marar, A. (2019, February 14). Upper caste Hindus richest in India, own 41% of total assets; STs own 3.7%, says study on wealth distribution. The Indian Express. https://indianexpress.com/article/india/upper-caste-hindus-richest-in-india-own-41-total-assets-says-study-on-wealth-distribution-5582984/
9. The laws of Manu and what they would mean for citizens of the Hindu Rashtra. (n.d.). The Wire. https://thewire.in/rights/manusmriti-hindu-rashtra-rss
10. Testbook. (2023). Hunter Commission (1882 & 1919) - Formation & Objectives for UPSC. Testbook. https://testbook.com/ias-preparation/hunter-commission
11. The Law Code of Manu. (n.d.). Google Books. https://books.google.co.in/books
12. Wikipedia contributors. (2023b). Mandal Commission. Wikipedia.
13. Mandal Commission. (n.d.). Drishti IAS. https://www.drishtiias.com/daily-updates/daily-news-analysis/mandal-commission-1
14. https://en.wikipedia.org/wiki/Caste
15. HugeDomains.com. (n.d.). https://www.hugedomains.com/domain_profile.cfm?d=simplydecoded.com
16. Express News Service. (2015, August 31). Sunday Story: Mandal Commission report, 25 years later. The Indian Express. https://indianexpress.com/article/india/india-others/sunday-story-mandal-commission-report-25-years-later/
17. National Commission for Backward Classes. (n.d.). http://www.ncbc.nic.in/User_Panel/UserView.aspx?TypeID=1161
18. Express News Service. (2015b, August 31). Sunday Story: Mandal Commission report, 25 years later. The Indian Express. https://indianexpress.com/article/india/india-others/sunday-story-mandal-commission-report-25-years-later/
19. Express News Service. (2015c, August 31). Sunday Story: Mandal Commission report, 25 years later. The Indian Express. https://indianexpress.com/article/india/india-others/sunday-story-mandal-commission-report-25-years-later/
20. The Constitution (One Hundred and Twenty Fourth Amendment) Bill, 2019. (n.d.). PRS Legislative Research. https://prsindia.org/billtrack/the-constitution-one-hundred-and-twenty-fourth-amendment-bill-2019
21. Chowdhury, S. R. (2019, January 11). Meet the group that has challenged the 10% reservation for upper castes in the Supreme Court. Scroll.in. https://scroll.in/article/909004/meet-the-group-that-has-challenged-the-10-reservation-for-upper-castes-in-the-supreme-court
22. Writ Petition (Civil) No. 55 OF 2019
23. 1963 AIR 649, 1962 SCR Supl. (1) 439
24. 1976 AIR 490, 1976 SCR (1) 906
25. 1985 AIR 1495, 1985 SCR Supl. (1) 352
26. https://www.clearias.com/indian-polity/
27. The Editors of Encyclopaedia Britannica. (2023, September 19). Planning Commission | Economic Development, Policy Making & Reforms. Encyclopedia Britannica. https://www.britannica.com/topic/Planning-Commission
28. Sharma, M. (2022, December 12). Reserving The Verdict: How Have Courts Ruled On Reservation And Why EWS Quota Has Raised Concerns. https://www.outlookindia.com/. https://www.outlookindia.com/national/how-have-courts-ruled-on-reservation-over-the-years-what-are-concerns-on-ews-reservation-news-244184
29. Supreme Court Observer. (2023, May 26). EWS reservation - Supreme Court observer. https://www.scobserver.in/cases/janhit-abhiyan-union-of-india-ews-reservation-case-background/
30. National Commission for Backward Classes. (n.d.-b). http://www.ncbc.nic.in/User_Panel/UserView.aspx?TypeID=1161
31. Government of India: Report of the Backward Classes Commission (Mandal Commission Report), Part 1, Vol. I, p. 56.
32. (2021) 8 SCC 1.
33. Indra Sawhney v. Union of India, 1992 Supp (3) SCC 217.
34. 1992 Supp (3) SCC 217, 735.
35. Jaishri Laxmanrao Patil v. Chief Minister, (2021) 8 SCC 1, 247.
36. 1992 Supp (3) SCC 217
37. ibid
38. Jaishri Laxmanrao Patil v. Chief Minister, (2021) 8 SCC 1, 247, para 475
39. 1992 Supp (3) SCC 217.
40. Jaishri Laxmanrao Patil v. Chief Minister, (2021) 8 SCC 1, 254, para 493.
41. V.V. Saminathan v. Govt. of T.N., 2021 SCC OnLine Mad 5646.
42. (2021) 8 SCC 1, 245, para 466.
43. (2006) 8 SCC 212.
44. Jaishri Laxmanrao Patil v. Chief Minister, (2021) 8 SCC 1.
45. Economically Weaker Section: Most Up-to-Date Encyclopedia, News & Reviews
    https://www.clearias.com/reservation-economically-weaker-sections-ews-quota/

Written By: Mihir Manish Linge, B.A.L.L.B[Hons] Semester V - Maharashtra National Law University, Aurangabad