Vertical and Horizontal Reservations

The reservation policy in India mentions two types of reservations:

1. Horizontal Reservations
2. Vertical Reservations

Based on these criteria, the recruitment to government jobs and other competitive exams is done in the country.

Know about Reservations in India, their introduction, quota, percentage and laws formulated for the same, at the linked article. 

Why is it in the news?

In January 2021, in the Saurva Yadav vs the State of Uttar Pradesh case, the Supreme Court gave its judgment against the Uttar Pradesh government. It has clarified the position of law on the interplay of vertical and horizontal reservations.

In this article, we shall discuss in detail the two types of reservation and the basis of the Supreme Court’s judgment in this case. It is an important topic from the IAS Exam perspective. 

Difference Between Vertical and Horizontal Reservations

What are Vertical Reservations?

Reservation for Scheduled Castes, Scheduled Tribes, and Other Backward Classes is referred to as vertical reservation. It applies separately for each of the groups specified under the law. This is mentioned in Article 16(A) of the Indian Constitution.

What are Horizontal Reservations?

It refers to the equal opportunity provided to other categories of beneficiaries such as women, veterans, the transgender community, and individuals with disabilities, cutting through the vertical categories. It comes under Article 15(3) of the Indian Constitution.

Vertical and Horizontal reservation – Explanation

1. Where a vertical reservation is made in favor of a Backward Class under Article 16(4), the candidates belonging to such Backward Class, may compete for non-reserved posts,
2. If they are appointed to the non-reserved posts on their own merit, their number will not be counted against the quota reserved for the respective Backward Class.
3. Therefore, if the number of SC candidates, who by their own merit, get selected to open competition vacancies, equals or even exceeds the percentage of posts reserved for SC candidates, it cannot be said that the reservation quota for SCs has been filled.
4. The entire reservation quota will be intact and available in addition to those selected under the open competition category.
5. But the aforesaid principle applicable to vertical reservations will not apply to horizontal reservations. Where a special reservation for women is provided within the social reservation for Scheduled Castes.
6. The proper procedure is first to fill up the quota for Scheduled Castes in order of merit and then find out the number of candidates among them who belong to the special reservation group of “Scheduled Caste women”.
7. If the number of women in such a list is equal to or more than the number of special reservation quota, then there is no need for further selection towards the special reservation quota.
8. If there is any shortfall, only then, the requisite number of Scheduled Caste Women shall have to be taken by deleting the corresponding number of candidates from the bottom of the list relating to Scheduled Castes.
9. To this extent, horizontal reservation differs from vertical reservation. Thus women selected on merit within the vertical reservation quota will be counted against the horizontal reservation for women.

Candidates can go through the following links to help themselves prepare for upcoming UPSC exams even better –

Can the two quotas be applied together?

One of the biggest questions which arise in regard to these two types of reservations is that can the vertical and horizontal quota be applied together? For example, a woman belonging to the Scheduled Caste category will get the reservation percentage under horizontal or vertical quota?

The answer to this is, the horizontal quota is always applied separately to each vertical category, and not across the board, i.e., if a woman has a 50% horizontal quota, then, half of all the selected SC candidates will necessarily have to be women.

Also visit Reservation demands: RSTV The Big Picture

Saurav Yadav vs The State of Uttar Pradesh Case

What was the case?

Saurav Yadav versus State of Uttar Pradesh 2020 dealt with issues arising from the way different classes of reservation were to be applied in the selection process to fill posts of constables in the state.

Sonam Tomar scored 276.59 marks and Rita Rani had secured 233.1908 marks. They had applied under the categories of OBC-Female and SC-Female respectively. OBC and SC are vertical reservation categories, while Female is a horizontal reservation category.

The issue with this was that these two candidates did not qualify, however, a girl with 274.82 marks and belonging to the general category had qualified for the exam. A question is raised here on the reservation policy for the examination. 

What was the Supreme Court’s Judgement?

The court ruled against the Uttar Pradesh government, stating that if a person belonging to an intersection of the vertical-horizontal reserved category had secured scores high enough to qualify without the vertical reservation, the person would be counted as qualifying, and cannot be excluded from the horizontal quota in the general category.

This was as a counter answer to the UP government’s policy to restrict and contain reserved category candidates to their own categories. 

Court’s Reasoning

1. If both vertical and horizontal quotas were to be applied together, a high-scoring candidate who would otherwise qualify without one of the two reservations is knocked off the list — then the overall selection would have candidates with lower scores.
2. On the other hand, if a high-scoring candidate is allowed to drop one category, the court found that the overall selection would reflect more high-scoring candidates.
3. In other words, the “meritorious” candidates would be selected.

Given below are links to the commissions which have been formed for the social and economic welfare of the backward classes:

To get the latest prelims and mains UPSC Syllabus for the upcoming Civil Services Exam, candidates can visit the linked article.

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