1. Dhanulanka is a sovereign, secular, independent republic nation.

The history of
Dhanulanka is deeply intertwined with the variegated caste system that has existed for
millennia, shaping the social, political, and cultural contours of the nation. The caste
system, a complex hierarchical structure, was historically rooted in the ancient Hindu
social order, with people categorized into distinct groups or "jatis" based on their
occupation, birth, and social status. This system became entrenched over time, leading
to significant social stratification, inequality, and discrimination. The system was
initially conceived as a division of labour and duties, dividing society into four broad
groups, however, over time, this system became more rigid, with individuals born into
specific castes or sub-castes, and their roles became hereditary. This led to the
formation of thousands of sub-castes, known as "jatis." The caste system became
hierarchical, with those at the bottom, the "untouchables", facing severe social
exclusion, discrimination, and violence. The impact of caste on Dhanulankan society
was profound, affecting access to resources, education, employment, and social rights.
2. When the Constitution of Dhanulanka was drafted in the 1940s, the framers of the
Constitution were acutely aware of the pervasive effects of the caste system on
Dhanulankan society and the need to address its legacy of discrimination. The
inclusion of provisions to counter caste-based discrimination was essential to the
vision of a just and equitable society. The framers of the Constitution were deeply
committed to creating a democratic society based on the ideals of justice, liberty,
equality, and fraternity. The Preamble of the Constitution reflects this commitment to
securing social, economic, and political justice for all citizens. Various articles of the
Constitution guarantee equality before the law, and were designed to prevent
discrimination based on caste, religion, or gender.
3. The framers of the Constitution acknowledged that merely declaring equality was not
sufficient in a society where caste-based discrimination was widespread. As a result,
the Constitution provided for special provisions to uplift those who had been
historically disadvantaged. To address the socio-economic backwardness of certain
castes, the Constitution allowed for reservations in legislatures, education, and public
employment. These provisions were included under the Dhanulankan Constitution,
reflecting a deliberate effort to level the playing field for marginalized communities.
The reservation system was seen as a temporary measure to correct centuries of
historical injustice. Though controversial at times, the system has played a crucial role
 in improving access to education, jobs, and political participation for historically
oppressed communities.
4. The Vijay community is a significant indigenous group in Dhanulanka, primarily
concentrated in the southeastern and eastern parts of the state. Historically, the Vijay
people, who belong to the Scheduled Tribes (ST) category in Dhanulanka, have faced
socio-economic and educational challenges. Their existential history dates back to
1560’s when they were forest-dwellers and closed group migrants. Over time, the
term "Vijay" has come to include a diverse range of ethnic sub-groups with distinct
cultural practices, language, and occupation, but they share a common historical
experience and roles of forest dwellers or selling of forest produce. The decision to
include the Vijay people in the ST category was made on the basis of their tribal
identity, which was characterized by their distinctive cultural practices, occupation,
social structure and perpetuity in terms of continuing their occupation by successive
generations. Because of this behaviour of the community, the did not attend formal
education in modern school setups and have never been part of education-based pubic
employments. In 2005, many newspapers and documentaries have shown-cased their
historical marginalisation and poor literacy rate which was hardly 17.5% for whole
community.
5. Article 342 of the Dhanulankan Constitution empowers the President to notify which
communities will be recognized as Scheduled Tribes in a particular state or across
nation. The Vijay community was officially included in the Centre list of Scheduled
Tribes in the year 1961 based on their historical and socio-economic marginalization.
This inclusion ensured that members of the Vijay community were entitled to
reservation benefits in educational institutions, government employment, and
legislative representation. However, since the community is not largely into
mainstream the percolation of benefits could not reach to them.
6. The government introduced a new policy of reservation in 2021 based on population-
census of 2011 where the population of the community was identified as 9 percent of
total population of nation and 22 percent of total population of ST’s. This policy
mandates a special quota for individuals belonging to the 'Vijay' caste in all Centre-
sponsored educational institutions, government jobs, and public sector enterprises.
The policy offers the 'Vijay' caste members a fixed 3% reservation within the ST
reservation of 7.5 % in every job (wherever ST quota is applicable) and university
across the state, regardless of their economic background.
7. Due to rampant protest, the policy got deferred but it ultimately came into force on
January 1, 2024, with the intent to uplift the 'Vijay' caste community, which the state
claims have been historically marginalized and economically disadvantaged. This
reservation policy has stirred controversy. Many people belonging to other
communities, particularly the 'Dhanav' and ‘Agarwari' tribes, have raised concerns,
arguing that they too have faced historical discrimination, but the state has failed to
include them in any such affirmative action schemes. They contended that they have
been in existence from 16th century as well and have same occupational and
behavioural history. They have been selling forest produces historically and have
earned based on that business. Many from these communities are poor and have been
deprived of formal education. As the policy also includes no income-based criterion,
leaving even the wealthiest individuals from the 'Vijay' community eligible for the
benefits, while economically disadvantaged people from the 'Dhanav' and 'Agarwari'
castes, who do not belong to a recognized backward class, do not qualify for any
benefits.
8. An organization representing the 'Dhanav' and 'Agarwari' tribes, called Vastav (Voice
Against Social Tyranny and Affirmative Value), filed a petition in the Supreme Court
under Article 32 challenging the constitutional validity of the reservation policy on the
grounds of discrimination, arbitrariness, and violation of the Right to Equality under
Article 14 of the Constitution of Dhanulanka. The petitioners argue that the policy is
discriminatory in nature because it treats individuals from different tribes unequally
without a justifiable basis, fails to adhere to the test of reasonable classification, and is
arbitrary in its implementation. They argue that the policy provides an unfair
advantage to the 'Vijay' caste members without properly addressing their actual social
or economic status and if status is to be applied then ‘Dhanav’ and ‘Agarwari’ must
also be included. Their second contestation is in relation to creation of a sub-quota of
3% expressly for Vijay community within the allocated quota of 7.5% of ST
community.
9. The Union of Dhanulanka has contested the challenge made by the petitioner. Their
primary contention is asserting that it is a valid exercise of the state's power to provide
affirmative action to underprivileged and historically disadvantaged communities
under Article 15 (4) and 16(4). The government claims that the policy aims to remedy
past injustices suffered by the 'Vijay' community and that the distinction made
between the 'Vijay' caste and other communities is based on a legitimate social and
 historical classification. They argue that the policy has already been delayed due to
protests and is not arbitrary, as mechanism for their social and educational upliftment.
Moreover, creation of sub-quota is based upon high population percentage of the
community.
10. Hon’ble Supreme Court has framed the following issues that would dispose of the
petition:

I. Whether the policy is based on a reasonable classification, fulfilling the

II. Whether the policy violates the doctrine of arbitrariness as defined by the
Supreme Court in various judgments?

III. Whether the certation of a sub-quota for one community within ST community
is permissible within the affirmative framework of the Constitution?