The High Court of Telangana has directed municipal authorities to reconsider the allocation of Scheduled Tribe (ST) reserved wards in Mahabubnagar Municipal Corporation in light of documented population growth. The order emphasizes that constitutional obligations under Articles 243T and 243Y require proportional representation, not static allocations based on outdated data.
The Verdict
The petitioner succeeded in securing an interim direction. The Court ordered Respondents 2 and 4 - the Commissioner and Director of Municipal Administration and the Mahabubnagar Municipal Corporation - to reconsider the petitioner’s representation for increasing ST-reserved wards in proportion to the rise in ST population, as reflected in official records. They must afford the petitioner a hearing and issue orders within ten days. The matter is listed for final hearing on 18 February 2026.
Background & Facts
The petitioner, a resident of Mahabubnagar, challenged a notification issued by the State Government on 11 January 2026, which retained the existing number of wards reserved for Scheduled Tribes in the Mahabubnagar Municipal Corporation. This notification was issued despite a significant increase in the ST population since the last delimitation exercise, as evidenced by the 2011 Census and subsequent demographic surveys.
The petitioner contended that the reservation of wards under the 73rd and 74th Constitutional Amendments must be dynamically aligned with demographic realities. The current allocation, based on data from decades prior, rendered the ST community’s political representation disproportionately low relative to its population share.
The petition was filed under Article 226 of the Constitution, seeking a writ of mandamus to compel the respondents to revise the ward reservation pattern. An accompanying interim application under Section 151 of the Code of Civil Procedure sought a stay on the implementation of the notification pending final disposal.
The respondents, including the State Government, Municipal Administration, State Election Commission, and District Collector, opposed the petition on grounds of procedural compliance and administrative finality, asserting that the notification followed established guidelines.
The Legal Issue
The central question was whether the constitutional mandate under Articles 243T and 243Y to reserve wards for Scheduled Tribes in municipal corporations requires a static allocation based on historical data, or whether it obligates authorities to periodically revise reservations in proportion to the current population share of ST communities.
Arguments Presented
For the Petitioner
The petitioner’s counsel argued that Articles 243T and 243Y of the Constitution, read with the Telangana Municipal Corporations Act, impose a continuing duty to ensure substantive representation. He cited the Supreme Court’s decision in State of Madhya Pradesh v. Nandlal Jaiswal (2016), which held that reservation must reflect the actual proportion of the community in the population to avoid perpetuating historical exclusion. He further relied on the 2011 Census data and the State’s own demographic reports showing a 37% increase in ST population in Mahabubnagar since 2001. The petitioner emphasized that failure to adjust ward reservations violates the principle of equality under Article 14 and the directive to ensure effective participation under Article 243Y.
For the Respondent
The respondents contended that ward reservation is a one-time exercise governed by the delimitation notification issued under the State Election Commission’s authority. They argued that the 2026 notification was issued in accordance with the statutory procedure and that any revision would require a fresh delimitation process, which is not currently underway. They further asserted that the petitioner’s claim was premature and that the existing reservation, though based on older data, was not arbitrary or unconstitutional.
The Court's Analysis
The Court rejected the notion that constitutional reservation is a frozen allocation. It held that Articles 243T and 243Y are not procedural formalities but substantive guarantees of political inclusion. The Court observed that the purpose of reservation in local bodies is to ensure that historically marginalized communities are not rendered politically invisible due to demographic shifts.
"The constitutional mandate under Article 243T is not a one-time administrative formality but a dynamic obligation to ensure that the representation of Scheduled Tribes in municipal governance remains proportionate to their population growth. To treat it otherwise would render the guarantee illusory."
The Court distinguished the respondents’ reliance on past delimitation exercises, noting that those exercises were conducted under different population baselines and did not contemplate the absence of future review. It emphasized that the State Election Commission, as the constitutional authority under Article 243K, has the duty to periodically reassess reservation patterns in light of updated census data.
The Court further held that the petitioner’s representation, submitted on 20 January 2026, raised a prima facie case of violation of constitutional rights. The failure to consider this representation within a reasonable time, especially when supported by official demographic data, amounted to a breach of the duty to act fairly under Article 14.
What This Means For Similar Cases
This interim order establishes a clear precedent: municipal corporations across India must not rely on outdated demographic data to fix ST and SC ward reservations. Authorities are now on notice that constitutional obligations under Articles 243T and 243Y require periodic reassessment of reservation quotas in light of population changes. Practitioners representing marginalized communities can now invoke this judgment to challenge static reservation patterns in any municipal body where demographic shifts are documented.
However, the ruling is interim and does not mandate a specific percentage increase. The final determination will depend on the proportionality analysis conducted by the municipal authorities after hearing the petitioner. Future litigants should ensure they submit certified population data from the Census or State Statistical Bureau to substantiate claims. This judgment does not override the statutory delimitation process but requires it to be informed by current realities.
The Court’s emphasis on procedural fairness - affording a hearing before revising reservations - also reinforces the principle that administrative decisions affecting constitutional rights must be transparent and participatory.
