Supreme Court of India· 06 August 2026

Does confining the Scheduled Areas jurisdictional bar to disputes involving tribal interest, rather than every dispute located within the notified area, satisfy the Article 14 requirement of reasonable classification?

MUKKERA VENKATA RATNAM & ORS v. VANTASALA CHINA VENKATESWARLU & ORS

2026 INSC 810 · C.A. No(s). .... of 2026 (@ SLP(C) Diary No. 21610 of 2022)
Coram: Sanjay Karol; Nongmeikapam Kotiswar Singh

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Answer

Yes. Restricting the exclusion to disputes engaging tribal interest, instead of applying it to the entire geographical area regardless of who the parties are, rests on an intelligible differentia bearing a rational nexus with the object of protecting Scheduled Tribes and their property; a blanket exclusion covering purely non-tribal disputes would not be a reasonable classification.

Headnote

Andhra Pradesh Civil Courts Act, 1972 — Scheduled Areas — Civil Court jurisdiction — Constitution of India — Article 14 — Reasonable classification — Binding precedent — Precedent — Binding precedent distinguished from judicial deference to the executive — Held: An order that merely defers to an executive committee's view, without independently discussing the provision's intent and objective, is not binding precedent on that point. (¶9) Andhra Pradesh Civil Courts Act, 1972 — Scheduled Areas notification — Civil Court jurisdiction over non-tribal disputes — Held further: The Scheduled Areas jurisdictional bar protects tribal interests; where every party to a civil dispute is non-tribal, no tribal interest is engaged and the Civil Court retains jurisdiction under Section 9 CPC. (¶13) Constitution of India — Article 14 — Reasonable classification — Intelligible differentia — Held further: Confining the bar to disputes engaging tribal interest, rather than the entire notified area regardless of the parties, rests on an intelligible differentia with a rational nexus to protecting Scheduled Tribes. (¶12, 13) Andhra Pradesh Civil Courts Act, 1972 — Scope of Agency Court jurisdiction — Held further: This applies only to pending and future cases, and restores Civil Court jurisdiction solely where every party is non-tribal; Agency Courts retain jurisdiction wherever even one party is a tribal. Appeal allowed. (¶14, 15, 16)

In the Court's own words

Paragraph 12The history of this legislation, its enactment and subsequent judicial developments have been noted by K. Ramaswamy J. in Samatha v. State of A.P.[^13]:

Paragraph 13We have arrived at this view for a very simple reason. When the object sought to be achieved by agency courts continuing in the Scheduled Areas is to protect the tribal people, the tribal property, their customs and practices, what is achieved by subjecting non- tribal people in that area to such special procedure? There is only one answer. Nothing. Admittedly, both the parties to this dispute are non-tribals. Then, what is the rational nexus of asking them to abide by procedures not intended for them? Rational nexus, as it is well known, is one of the grounds which is to be considered when looking at a particular dispute through the lens of Article 14 of the Constitution. Being a part of the golden triangle of the Constitution, this article provides for equality before the law and equal protection of the law. The principle is that all persons subject to the legislation should be placed on the same pedestal regarding privileges and liabilities conferred and imposed by the statute, respectively, provided that the circumstances governing them are also the same. On the face of it, Article 14 would be violated since it is specifically intended for securing the rights of indigenous communities but is being applied to people not amongst them. It does not bear nexus to the object, which indubitably was to protect people from these communities from exploitation by those who are worldly wise. Since in the present facts, neither of the parties is a member of the Scheduled Tribe, nor are there any fetters of succession and partition amongst the co-sharers, it does not concur with reason to treat them as if they were members of the tribes solely on account of the land in question. The circumstances governing them cannot be called ‘like circumstances’.

Acts & Sections

Andhra Pradesh Civil Courts Act, 1972Art.14 Constitution of Indias.9 Code of Civil Procedure, 1908Fifth Schedule Constitution of India

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Also decided in this judgment

What test determines whether a prior court order lays down a binding precedent on a point of law, as opposed to merely deciding the case before it?When only part of a judgment states the reasoning behind a conclusion, which part of that judgment binds later courts as precedent?Under the Andhra Pradesh Civil Courts Act, 1972 and the notification excluding Scheduled Areas, do ordinary Civil Courts have jurisdiction over a partition suit between parties who are all non-tribals, even though the suit property lies within a Scheduled Area?If even one party to a civil dispute over land in a Scheduled Area is a tribal, does the ordinary Civil Court retain jurisdiction under this ruling?

Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Supreme Court of India. Corrections