Reservation Must Follow Census, Not FIDR: Punjab & Haryana High Court Quashes Reduction of SC Seats in Panchkula MC
Case Name: Usha Rani & Ors. v. State of Haryana & Ors.
Date of Judgment: 08 April 2026
Citation: CWP No. 1307 of 2026
Bench: Hon’ble Mr. Justice Anoop Chitkara; Hon’ble Mrs. Justice Sukhvinder Kaur
Held: Reservation of seats for Scheduled Castes in Municipal Corporations must be strictly based on the last published Census as mandated under Articles 243P(g) and 243T of the Constitution. Reliance on Family Information Data Repository (FIDR) for such purpose is impermissible. Any deviation renders the notification unconstitutional.
Summary: The petitioners, former councillors of Municipal Corporation Panchkula, challenged the notification dated 04.09.2025 whereby the number of seats reserved for Scheduled Castes was reduced from 4 to 3 for the upcoming elections.
The core grievance was that the reduction was based on data derived from the Family Information Data Repository (FIDR), instead of the Census of 2011, which is constitutionally mandated for determining population in matters of municipal reservation.
The State contended that the reduction resulted from changes in geographical boundaries of the Municipal Corporation and was carried out in accordance with statutory amendments, including reliance on FIDR data for population determination.
The Court examined the constitutional scheme under Articles 243P(g) and 243T, which mandate that population for reservation purposes must be based on the last preceding Census with published figures. It also considered the amendments to the Haryana Municipal Corporation Act and Delimitation Rules permitting use of FIDR data for certain purposes.
However, the Court found that while FIDR could be used for fixation of total seats or backward class reservations, it could not replace Census data for determining Scheduled Castes reservation. The State’s approach of using FIDR for total population while relying on Census selectively for Scheduled Castes resulted in an inconsistent and constitutionally flawed exercise.
The Court further held that proper exercise required recalculation strictly on the basis of 2011 Census data, adjusted to the altered geographical limits of the Municipal Corporation, which was not done.
Decision: The High Court held that the impugned notification suffered from constitutional infirmity as it failed to adhere to the mandate of Articles 243P(g) and 243T. The reliance on FIDR data for determining Scheduled Castes reservation was held to be impermissible, and the inconsistent methodology adopted by the State vitiated the entire exercise. The Court concluded that reservation of seats could only be determined on the basis of the last published Census, i.e., Census 2011, applied to the reconstituted municipal limits. Accordingly, the notification dated 04.09.2025, to the extent it reduced the Scheduled Castes reserved seats from 4 to 3 in Municipal Corporation Panchkula, was quashed.