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As per case facts, the State of Kerala failed to implement the Supreme Court's previous judgment on identifying and excluding the 'creamy layer' from Backward Classes for reservation benefits. Instead,
...Kerala enacted legislation in 1995, explicitly declaring that no 'creamy layer' existed within its Backward Classes and continued the existing reservation system without any exclusions. This legislative defiance prompted new writ petitions challenging the constitutionality of the Kerala Act, alleging violations of fundamental rights. The Court had previously directed the formation of a High Level Committee to identify the creamy layer in Kerala, which submitted a report confirming its existence. The state's action was seen as an attempt to circumvent judicial directives. The question arose whether the Kerala Act of 1995, which negated the existence of a 'creamy layer' and upheld an unamended reservation system, was constitutional and adhered to the principles established by prior Supreme Court judgments, especially concerning equality and non-discrimination. Specifically, the Court examined if legislative declarations could override established legal precedents regarding the identification and exclusion of the socially advanced sections from reservation benefits and whether such an act violated the basic structure of the Constitution. Finally, the Supreme Court ruled that sections of the Kerala Act were unconstitutional, arbitrary, and directly violated Articles 14 and 16 of the Constitution, as well as the fundamental principle of equality which forms part of the basic structure. The Court held that the legislative declaration denying the existence of a 'creamy layer' was a mere pretense, contrary to established facts and judicial pronouncements. It reaffirmed that the exclusion of the creamy layer is mandatory to ensure reservation benefits reach the truly deserving backward classes and to maintain administrative efficiency. The Court accepted the report of the High Level Committee that identified the creamy layer and ordered its immediate, prospective implementation, while also allowing the state a final opportunity to enact compliant legislation. The Court strongly criticized Kerala's actions as a deliberate disregard for the rule of law.
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