MP High Court: Women Married in Madhya Pradesh Must Obtain State-Issued OBC Certificate to Claim Reservation

The Madhya Pradesh High Court has ruled that women who migrate to Madhya Pradesh after marriage cannot claim OBC reservation benefits in State government employment solely on the basis of caste certificates issued by authorities in other States. The Court held that such candidates must obtain a caste certificate from the competent authority in Madhya Pradesh before seeking reservation benefits.

Justice Vishal Dhagat delivered the judgment while dismissing a petition filed by Sunita Pathode, Lalita Harinkhede, and Pooja Sahu. The petitioners challenged the rejection of their candidature for the post of Middle Teacher after authorities found that their OBC certificates had been issued in Maharashtra and Uttar Pradesh rather than Madhya Pradesh.

The petitioners argued that their communities—Kunbi, Pawar, and Teli—are recognised as Other Backward Classes both in their native States and in Madhya Pradesh. They contended that after marrying and permanently settling in Madhya Pradesh, they should not be denied reservation benefits merely because their caste certificates originated from another State.

The State opposed the plea, maintaining that reservation benefits in Madhya Pradesh require certification from the State’s competent authority. The Court agreed, observing that caste-based reservation is linked to State-specific notifications and verification procedures.

While recognising that women who relocate after marriage may be eligible for reservation if their caste is recognised in both States, the Court clarified that eligibility can only be established through a caste certificate issued by Madhya Pradesh authorities. It specifically held that a caste certificate issued in Maharashtra or Uttar Pradesh cannot be relied upon for claiming reservation in Madhya Pradesh services.

Since the petitioners had never applied for or obtained caste certificates from Madhya Pradesh, the Court found no illegality in the rejection of their candidature and dismissed the writ petition.

Case: Sunita Pathode & Others v. State of Madhya Pradesh & Others

Court: Madhya Pradesh High Court

Judge: Justice Vishal Dhagat

Decision Date: 16 June 2026.