LIJDLR

Local Self-Government

CASE ANALYSIS: KARNAIL SINGH AND ANOTHER V. DARSHAN SINGH AND OTHERS (1995) SUPP (2) SCC 281 (SC)

CASE ANALYSIS: KARNAIL SINGH AND ANOTHER V. DARSHAN SINGH AND OTHERS (1995) SUPP (2) SCC 281 (SC) Senthamizh Vijayakumar, 3rd Year, Student at VIT School of law (India) Satvik Keyan, 3rd Year, Student at VIT School of law (India) Dr.Saji Sivan S, Associate Professor at VIT School of law (India) Download Manuscript doi.org/10.70183/lijdlr.2026.v04.69 The case of Karnail Singh and Another v. Darshan Singh and Others (1995) relates to the powers of the State Government in reorganizing and amalgamating the Gram Sabhas as per the Punjab Gram Panchayat Act, 1952. The case arose when the Haryana Government issued a notification for the amalgamation of two Gram Sabhas as a single unit for administrative purposes in the district of Kurukshetra. The respondents challenged the government’s decision before the Punjab and Haryana High Court, which set aside the government’s decision on the basis that the functioning of the Gram Sabhas should not be interfered with merely due to the abuse of power by local government officials. The case was later referred to the Supreme Court of India. The Supreme Court was called upon to examine the question of whether the government had the powers to reorganize the Gram Sabha areas as per the relevant statutory provisions and whether such decisions could be interfered with by the judiciary. The judgment reiterated the discretionary powers of the government in reorganizing the local self-governments for the better administration of the regions.

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CASE ANALYSIS: VIKAS KISHANRAO GAWALI V. STATE OF MAHARASHTRA (2021) 6 SCC 73

CASE ANALYSIS: VIKAS KISHANRAO GAWALI V. STATE OF MAHARASHTRA (2021) 6 SCC 73 S. Akash, B.B.A.LLB/3rd year/6th semester Student at VIT School of Law, VIT Chennai (India) Mukeshwaran, B.B.A.LLB/3rd year/6th semester Student at VIT School of Law, VIT Chennai (India) Dr. Saji Sivan S, Assistant professor, VIT School of Law, VIT Chennai (India) Download Manuscript doi.org/10.70183/lijdlr.2026.v04.65 The decision in Vikas Kishanrao Gawali v. State of Maharashtra represents a significant development in the constitutional jurisprudence relating to political reservations in local self-government institutions in India. The litigation arose from a challenge to the constitutional validity of the reservation framework for Other Backward Classes (OBCs) in local bodies in Maharashtra, particularly the operation of Section 12(2)(c) of the Maharashtra Zilla Parishads and Panchayat Samitis Act, 1961, which enabled reservation for backward classes in such institutions. The petitioner contended that the State had implemented OBC reservation without conducting a contemporary empirical inquiry demonstrating political backwardness and that the resulting reservation exceeded the constitutionally permissible limit. The Supreme Court examined the scope of political reservations under Articles 243D and 243T of the Constitution of India in light of the equality guarantee under Article 14. Relying on the precedent in K. Krishna Murthy v. Union of India, the Court reaffirmed the “triple test,” which requires the constitution of a dedicated commission to undertake an empirical study of backwardness, determination of the extent of reservation on the basis of such data, and adherence to the overall 50 percent ceiling on reservations. The Court held that the State of Maharashtra had failed to satisfy these constitutional requirements and consequently declared the OBC reservations in local bodies invalid until the triple test conditions were fulfilled. The judgment highlights the need to balance the objective of social justice with constitutional limitations, and it remains a significant precedent in shaping the relationship between equality, representation, and decentralised democracy in India.

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