Full chapter text
Middle Classes
Reservation became one of the principal institutions through which the democratic state attempted to
alter inherited inequalities in education, public employment and representation. In Bihar this history is
unusually layered. Scheduled-Caste and Scheduled-Tribe safeguards intersected with backward-class
commissions, the Karpoori Thakur formula, Mandal politics, a statutory division between Extremely
Backward Classes and Backward Classes, women’s and other horizontal reservations, local-government
quotas, welfare hostels, scholarships, examination support and, later, an Economically Weaker Sections
quota. Across the border, Nepal developed a different but comparable inclusion system in which Madhesi
representation became part of civil-service and federal-democratic reform.
This chapter is not a legal digest and does not assume that a reserved seat automatically produces equality.
Its historical question is how affirmative action changed pathways into education, bureaucracy, teaching,
policing, technical employment, elected local office and professional life, and how these pathways helped
create new salaried, credentialled and politically connected middle strata among communities previously
weakly represented in state institutions. It also asks who remained outside these gains, why intra-category
inequality became a recurring political question, and how the shrinking relative weight of secure public
employment changed the meaning of reservation itself.
95.1 The Constitution transformed exclusion into a question of public
representation
The Constitution abolished untouchability and prohibited discrimination while also permitting special
measures for historically disadvantaged groups. Article 16(4) allowed reservation in public employment for
backward classes not adequately represented in state services; the First Amendment of 1951 inserted Article
15(4), enabling special provisions for socially and educationally backward classes as well as Scheduled Castes
and Scheduled Tribes. The resulting framework did not erase caste from public life. It moved caste into a
new institutional language of backwardness, representation, equality and state responsibility. In Bihar, where
access to education and administration had long been socially concentrated, these provisions created a
constitutional route through which groups could demand a share in the modern state.
95.2 Scheduled-Caste and Scheduled-Tribe reservation opened early channels
into the postcolonial state
The earliest reservation architecture after independence concentrated on Scheduled Castes and Scheduled
Tribes. Its effects were uneven but historically important: government service, teacher recruitment, technical
education and public institutions became possible sites of first-generation mobility. A reserved vacancy did
not remove poor schooling, landlessness or discrimination, and many rural households remained too far from
the credential threshold to compete. Yet the presence of even a small cohort of teachers, clerks, police
personnel and other public employees altered village status relations because salaries, pensions, bureaucratic
literacy and urban connections could accumulate across a generation. This is one foundation of the later
Dalit middle class discussed here.
HISTORY OF MITHILA, VAJJI & ANGA — VOLUME II
95.3 Bihar’s backward-class question preceded the national Mandal moment
Backward-class mobilisation in Bihar did not begin in 1990. The state had already experienced non-
Brahman and backward-caste organisation, socialist politics and repeated arguments over administrative
representation. The Mungeri Lal Commission, appointed in 1970 and reporting in 1976, classified a large set
of backward communities and distinguished a more disadvantaged segment. This distinction was historically
consequential because it challenged the idea that all backward classes had equal access to political
organisation, land, education or state employment. It prepared the ground for a sub-categorised reservation
formula before the Union government implemented the Mandal Commission recommendations.
95.4 The Karpoori formula institutionalised unequal backwardness within the
backward classes
In 1978 the Karpoori Thakur government introduced a graded reservation formula rather than treating
the backward classes as a single bloc. The best-known formulation allocated 12 per cent to the most or
extremely backward segment, 8 per cent to other backward classes, 3 per cent to women and 3 per cent to
economically weaker persons outside the main backward categories. The precise administrative labels evolved
later, but the principle endured: numerical and political strength within a broad “backward” category could
itself produce unequal access to reservation benefits. Bihar’s later separation of EBC and BC quotas owes
much to this institutional imagination.
Figure 376 — Major institutional thresholds in Bihar’s affirmative-action history
95.5 Mandal converted a regional struggle into a national restructuring of
representation
The Second Backward Classes Commission under B. P. Mandal submitted its report in 1980 and
recommended 27 per cent reservation for Other Backward Classes in central services. Implementation in
1990 reorganised political competition across north India. In Bihar, however, Mandal interacted with an
already mature politics of backward representation. The effect was therefore not simply to create an OBC
category but to intensify competition within it: large agrarian castes, smaller service and artisan communities,
and extremely backward groups did not possess the same educational capital or organisational networks.
Reservation became both an instrument of mobility and a field of intra-backward politics.
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95.6 Indra Sawhney made the creamy layer and the 50 per cent rule central to
quota administration
The Supreme Court’s 1992 Indra Sawhney judgment upheld OBC reservation while requiring exclusion
of the socially advanced “creamy layer” among OBCs and treating 50 per cent as the normal outer limit for
reservation under Articles 15(4) and 16(4), subject to exceptional circumstances. This judicial framework
shaped Bihar’s later reservation debates. It also made documentation more important: caste certificates, non-
creamy-layer certificates, income evidence and recruitment rosters became part of everyday mobility. The
bureaucratic ability to prove eligibility thus became a new form of social capital, especially for first-
generation applicants navigating complex state procedures.
95.7 The Bihar reservation statute created a durable post-Mandal category
structure
The Bihar Reservation of Vacancies in Posts and Services Act, 1991, as modified after the state’s
bifurcation, established a 50 per cent vertical framework comprising 16 per cent Scheduled Castes, 1 per cent
Scheduled Tribes, 18 per cent Extremely Backward Classes, 12 per cent Backward Classes and 3 per cent
Women of Backward Classes. The 2002 amendment reflected the reduced Scheduled-Tribe share after
Jharkhand’s creation while raising Scheduled-Caste and EBC shares. This architecture mattered beyond
percentages: it formally separated EBC from BC and thereby gave administrative reality to a distinction long
central to Bihar’s politics.
95.8 Reservation benefits candidates only after they cross earlier educational
filters
A quota operates at admission or recruitment, not at every stage that produces an eligible candidate. A
rural student must first complete school, obtain documents, pay for travel or coaching, learn the relevant
examination language and remain available for a long recruitment cycle. This is why Chapters 84 and 94 are
indispensable to the history of reservation. Scholarships, hostels, residential schools, pre-examination training
and direct benefit transfers do not replace reservation; they help applicants reach the point at which
reservation can matter. The emergence of new middle strata is therefore produced by a chain of institutions
rather than a single roster.
Figure 377 — From affirmative action to new middle-class formation
HISTORY OF MITHILA, VAJJI & ANGA — VOLUME II
95.9 Public employment created distinctive forms of security and authority
The social power of reservation was magnified by the character of public employment. A government
salary was regular; many posts carried pension rights or other retirement benefits; employment generated
access to banks, housing, urban residence, information and formal documents. In villages, a teacher, clerk,
police employee, railway worker or lower-level officer could become a broker between relatives and
bureaucratic institutions. This did not automatically create wealth, but it often created stability. For
historically excluded families, the difference between irregular agricultural labour and a salaried public post
could be large enough to alter children’s schooling, marriage negotiations and residential aspirations within
one generation.
95.10 The “new middle class” is plural and should not be reduced to government
officers
Affirmative action helped generate several overlapping middle strata: salaried employees, school and
college teachers, nurses and technicians, local representatives, lawyers, welfare intermediaries, contractors,
students preparing for competitive examinations and households whose first secure job financed the next
generation’s private education. Some possess property; others are credential-rich but asset-poor. Some remain
closely tied to village agriculture; others live in district towns or migrate to metropolitan labour markets.
Treating all of them as one middle class obscures important differences in income, job security, caste network
and cultural capital. The more precise historical claim is that reservation widened entry into institutions from
which new class trajectories could develop.
95.11 EBC sub-categorisation aimed to prevent stronger backward groups from
monopolising access
Bihar’s separate EBC quota embodies a political diagnosis: backwardness is internally stratified.
Communities with little land, low literacy, scattered settlement or weak organisational networks may be
disadvantaged even within an OBC reservation system. A separate EBC category can therefore be understood
as an attempt to distribute access across unequal backward groups rather than only between “forward” and
“backward” society. At the same time, sub-categorisation creates its own boundary disputes because
inclusion in a list can influence education, recruitment and political identity. The state’s caste schedules are
thus not neutral descriptions; they are institutions that help organise social competition.
95.12 Creamy-layer rules reveal the tension between group disadvantage and
intra-group accumulation
Once reservation produces stable salaried households, a difficult question follows: should descendants of
the most advanced beneficiaries remain eligible on the same terms as first-generation applicants from poorer
households within the same category? The OBC creamy-layer rule is one response, using income and status
criteria to exclude advanced sections from specified reservation benefits. In practice the rule also creates
administrative complexity and recurring disputes over certificates, parental occupation and eligibility dates.
Historically, the very existence of the creamy-layer debate shows that affirmative action can create internal
differentiation inside beneficiary groups and that social justice policy must confront both inter-group and
intra-group inequality.
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Figure 378 — Bihar’s reservation architecture after the 2024 High Court judgment
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Table 95.1 — Major affirmative-action instruments and their social effects
Instrument Primary gateway Potential mobility Historical
effect limitation
SC/ST reservation education and public first-generation earlier schooling and
employment salaried and land inequality
professional entry remain
BC/EBC reservation state education and widens backward- unequal access within
recruitment class representation; categories;
EBC sub-category documentation
broadens reach burdens
Scholarships / hostels pre-selection pipeline helps candidates coverage and quality
/ coaching reach qualifying vary
thresholds
Local-body panchayat and leadership experience, office does not
reservation municipal political networks, guarantee control
representation public visibility over resources
EWS reservation education and public adds an income/asset- does not address
employment based route outside caste-based
caste-reserved groups disadvantage
Horizontal cuts across vertical widens interaction with
reservation categories representation of vertical rosters can be
women, disability complex
and other groups
Nepal inclusive civil public employment Madhesi, women, different legal
service Dalit and Janajati categories; not
access to the state directly comparable
to Bihar
95.13 Local-government reservation changed the geography of political
apprenticeship
Reservation in panchayats and municipalities created a different kind of mobility from a salaried job. It
brought representatives from Scheduled Castes, backward classes and women into institutions that allocate
local development resources, certify needs and mediate with the bureaucracy. Bihar’s local-government
framework reserves seats for SC/ST in relation to population and provides backward-class reservation subject
to statutory limits; women’s reservation became especially extensive. The result was a new arena of political
apprenticeship in which persons without old landed or party dynasties could acquire public visibility. Yet
formal office and effective power are not identical, and proxy control, bureaucratic dependence and local
hierarchy remain recurrent constraints.
95.14 Women’s horizontal reservation intersects with caste reservation rather
than sitting outside it
Horizontal reservations are designed to cut across vertical categories. A woman may simultaneously
belong to SC, ST, EBC, BC, EWS or open-merit categories, and roster design must allocate the horizontal
benefit without treating these identities as mutually exclusive. Bihar has used substantial horizontal
reservation for women in state recruitment and local government; a 2025 state order clarified the 35 per cent
horizontal reservation in direct appointments for women residents of Bihar. The social effect is important for
new middle-class formation because secure female employment can alter household bargaining, marriage
timing, investment in daughters and the gender composition of public offices.
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95.15 Scholarships, hostels and pre-examination programmes expand the
meaning of affirmative action
Reservation is often discussed as a seat or vacancy, but Bihar’s welfare departments operate a wider
infrastructure of post-matric scholarships, BC/EBC and SC/ST hostels, residential institutions, merit
incentives and pre-examination training. These programmes target the supply side of representation by
lowering the cost of remaining in education and competitive preparation. Their historical significance lies in
enabling first-generation students to spend time on credential accumulation rather than immediate wage
work. Where implementation is weak, however, the formal existence of a quota may coexist with low
applicant preparedness. The most effective affirmative-action system is therefore an ecosystem rather than a
single percentage.
95.16 The private sector limits the reach of the classic reservation model
The constitutional and statutory reservation systems discussed here primarily govern public employment
and specified educational institutions; they do not generally impose caste-based quotas across private
employment. As Bihar’s labour market shifted toward private schools, hospitals, retail, construction, small
services, platforms and migration-based work, the share of life chances directly allocated through public
rosters became limited. This changes the political economy of reservation. A public job may become more
valuable precisely because it is scarce, while a growing number of educated applicants must convert
credentials in labour markets where formal reservation does not operate. New middle-class formation
therefore increasingly combines state-enabled education with non-state employment.
95.17 Reservation can create information networks that extend beyond the
direct beneficiary
The first government employee or university entrant in a family often becomes an information node.
Relatives learn how to obtain caste and income certificates, where to apply for scholarships, how recruitment
calendars work, what subjects are useful and which cities provide coaching or hostels. Such knowledge can
diffuse through caste associations, village networks and alumni groups. Over time, the advantage created by
one successful entry can become cumulative. This is one reason reservation’s effect cannot be measured only
by the income of the individual beneficiary: institutional literacy itself can become an intergenerational asset
that reshapes the opportunity set of a wider kin network.
95.18 Reservation also changes marriage markets and status languages
A secure government or professional position can raise a household’s standing within its caste network
and beyond it. In marriage negotiations, salaried employment may command high demand, sometimes
intensifying dowry rather than weakening it. Educational and occupational status can also create new forms
of distinction within communities previously represented as socially homogeneous. Terms such as “officer
family,” “teacher family,” “service family” or “educated household” begin to supplement older land- and
lineage-based status. Reservation can therefore weaken some inherited monopolies while generating new
hierarchies of credential, salary and bureaucratic connection inside beneficiary communities.
95.19 The Mahadalit policy phase made intra-SC inequality a central Bihar
question
From the late 2000s Bihar’s Mahadalit policy framework targeted Scheduled-Caste communities
identified by the state as especially deprived through specialised welfare programmes. This was not simply
HISTORY OF MITHILA, VAJJI & ANGA — VOLUME II
another vertical reservation percentage; it reflected the argument that benefits reaching the Scheduled-Caste
category as a whole were unevenly distributed. The policy shifted attention toward landlessness, housing,
education, community infrastructure and access to schemes among the most marginalised Dalit groups. It
also generated political debate over classification, inclusion and whether welfare targeting should coexist with
or lead toward sub-classification in reservation. The historical point is that a broad constitutional category
increasingly had to confront internal social differentiation.
95.20 The 2024 Davinder Singh judgment reopened the legal space for SC sub-
classification
In State of Punjab v. Davinder Singh, a seven-judge Supreme Court bench in 2024 held that states may
sub-classify Scheduled Castes for the purpose of distributing reservation benefits, provided the classification
satisfies constitutional requirements and is grounded in relevant evidence. The decision overturned the
earlier bar associated with E. V. Chinnaiah. It did not automatically create a Bihar sub-quota, and different
judicial opinions raised separate questions about the creamy layer. For Bihar, however, the judgment is
historically significant because it provides a constitutional framework within which longstanding debates
over unequal benefit within the Scheduled-Caste category may be reformulated.
95.21 EWS added an economic route outside the traditional caste-reservation
categories
The 103rd Constitutional Amendment created a new basis for affirmative action: up to 10 per cent
reservation for Economically Weaker Sections outside the groups covered by existing SC, ST and backward-
class reservation. Bihar enacted its EWS reservation law in 2019 for state posts, services and admissions. The
Supreme Court upheld the constitutional amendment in Janhit Abhiyan. EWS does not replace caste-based
affirmative action; it operates on a different rationale and is additional to existing reservations. Its
introduction nevertheless altered public debate by making economic disadvantage an explicit reservation
criterion at constitutional scale and by expanding the social groups that engage with quota administration.
95.22 Bihar’s 2023 caste survey supplied new data but also sharpened the
representation dispute
The Bihar caste-based survey released in 2023 reported EBCs at about 36.01 per cent of the population,
BCs at 27.12 per cent, Scheduled Castes at 19.65 per cent and Scheduled Tribes at 1.68 per cent. The survey’s
importance lay not only in these shares but in the state’s attempt to connect demographic and socio-
economic evidence to affirmative-action policy. Supporters viewed the data as a basis for recalibrating
representation; critics argued that population proportion alone could not determine reservation under
Articles 15(4) and 16(4). The survey thus transformed caste data from an abstract demand into a concrete
policy instrument and a constitutional controversy.
95.23 The 2023 Bihar amendments attempted to raise SC/ST/EBC/BC reservation
to 65 per cent
Following the caste survey, Bihar amended its reservation laws in November 2023. The new distribution
raised Scheduled-Caste reservation to 20 per cent, Scheduled-Tribe reservation to 2 per cent, EBC reservation
to 25 per cent and BC reservation to 18 per cent, for a total of 65 per cent, while the separate 10 per cent
EWS framework continued. The state justified the change through the scale of social and educational
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backwardness and under-representation. The legislation represented the most ambitious attempt since
Mandal to align Bihar’s reservation structure more closely with newly measured social composition.
95.24 The Patna High Court struck down the 65 per cent amendment in June
On 20 June 2024 the Patna High Court invalidated the 2023 employment and educational-reservation
amendments. The court held that the enhancement beyond the 50 per cent ceiling was unconstitutional on
the record before it and criticised reliance on population proportion rather than a sufficient analysis of
adequate representation. The judgment returned Bihar’s legal framework to the pre-amendment position
unless and until higher judicial review changes that result. The dispute is important historically because it
demonstrates the continuing tension between demographic claims for proportional representation and the
constitutional doctrine of adequate representation under Articles 15 and 16.
95.25 As of August 2026, the 65 per cent dispute remained unresolved in the
Supreme Court
Bihar appealed the High Court judgment to the Supreme Court. The Supreme Court declined interim
relief in July 2024, so the High Court’s ruling was not stayed. The connected appeals continued to appear in
Supreme Court cause lists in 2026, and public reporting in August 2026 still described the state’s appeal as
pending. A contemporary history must therefore avoid presenting the 65 per cent scheme as either currently
operative or finally extinguished. Its legal status is an unresolved appellate dispute, and the older statutory
architecture remains the safer description of the operative vertical framework pending a contrary final order.
Figure 379 — Regional affirmative-action institutions and new middle-class formation
95.26 Nepal-side Madhesh followed a different inclusion path after 2007
The Nepal comparison is essential because Madhesh is part of the wider Mithila interaction zone but
operates under a different constitutional system. The 2007 amendment to Nepal’s civil-service framework
reserved 45 per cent of vacancies filled by open competition for inclusive categories; within that reserved
pool, the distribution included women, Adivasi/Janajati, Madhesi, Dalit, persons with disabilities and
backward areas. Madhesis received 22 per cent of the reserved pool. This arrangement cannot be translated
HISTORY OF MITHILA, VAJJI & ANGA — VOLUME II
mechanically into Bihar’s caste categories, but it similarly sought to alter the social composition of the state
bureaucracy. For families in Janakpurdham and Madhesh, public-service inclusion became another route
into credentialled middle-class status.
95.27 Federalisation expanded the political meaning of inclusion in Madhesh
Nepal’s 2015 Constitution strengthened the language of proportional inclusion and federal
representation. In Madhesh, inclusion therefore operates not only through civil-service recruitment but
through provincial institutions, electoral representation and debates over citizenship, language and state
identity. A Madhesi middle class has grown through education, public administration, professions, migration
and cross-border commerce as well as affirmative-action channels. The comparison with Bihar is useful
precisely because it reveals that “reservation” is not one universal mechanism: different political systems
combine quotas, representation, federalism and social classification in different ways while confronting a
common problem of historically unequal access to the state.
95.28 New middle classes can challenge old landed power without eliminating
class inequality
A teacher from an EBC family, a Dalit police employee, a BC engineer, a woman panchayat
representative or a Madhesi civil servant may acquire resources and authority that earlier depended more
heavily on land, lineage or established urban networks. This can diversify local leadership and weaken the
monopoly of older elites. Yet middle-class ascent also produces new inequalities within historically
disadvantaged communities. Secure employees may buy land, move to towns, send children to private
schools and develop networks unavailable to casual labourers of the same caste. Reservation therefore
redistributes opportunity while also creating internal class differentiation that later politics must address.
95.29 The future of affirmative action depends increasingly on educational
quality and the structure of work
The number of applicants with certificates and degrees has expanded much faster than the supply of
secure public posts. At the same time, automation, contractualisation, outsourcing and private-sector growth
reduce the share of employment directly governed by classic reservation rosters. This does not make
affirmative action irrelevant; it changes the complementary policies required. Better school learning,
affordable higher education, anti-discrimination enforcement, transparent recruitment, apprenticeships,
credit and private-sector opportunity become more important if the gains of reservation are to extend
beyond a limited salaried layer. The central challenge is to convert representation into broad capability rather
than a narrow competition for scarce state posts.
95.30 Reservation changed the social composition of aspiration even where
equality remains unfinished
Across Mithila, Vajji and Anga, reservation and allied affirmative action altered who could plausibly
imagine becoming a teacher, police officer, engineer, clerk, university student, local representative or
administrator. The result is visible in new middle strata whose authority rests on salaries, credentials, state
literacy and networks rather than only inherited land or ritual status. Yet the system remains filtered by
unequal schooling, documentation, gender, geography, vacancy scarcity and intra-category advantage. The
most accurate historical conclusion is therefore double: affirmative action has been a real engine of social
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mobility and democratic representation, and its benefits have never been evenly distributed. The politics of
reservation persists because both propositions are true at once.