Summary and Analysis of K. Purushottam Reddy vs. Union of India and Ors (Civil) No. 718 of 2022)

1. Heading of the Judgment

• Case Name: K. Purushottam Reddy vs. Union of India and Ors.

• Citation: 2025 INSC 894

• Writ Petition (Civil) No.: 488 of 2022 (with Writ Petition (Civil) No. 718 of 2022)

• Coram: Surya Kant, J. and Nongmeikapam Kotiswar Singh, J.

2. Related Laws and Sections

• Constitution of India: Articles 14, 32, 82, 170, 239A.

• Andhra Pradesh Reorganisation Act, 2014: Section 26.

• Jammu and Kashmir Reorganisation Act, 2019: Section 60.

• Delimitation Act, 2002: Section 3.

3. Basic Judgment Details

This judgment concerns two Writ Petitions filed under Article 32 of the Constitution of India challenging the legality of two notifications issued by the Union of India in 2020 and 2021. These notifications conducted a delimitation exercise for the Union Territory of Jammu and Kashmir, which resulted in an increase in the number of seats in its Legislative Assembly. The petitioners argued that the states of Andhra Pradesh and Telangana were arbitrarily excluded from a similar delimitation exercise. They sought a directive for the Union of India to increase the number of seats in the Legislative Assemblies of Andhra Pradesh and Telangana in line with the relevant statutory provisions.

4. Explanation of the Judgment

The core of the judgment in K. Purushottam Reddy vs. Union of India revolves around two main issues:

1. Whether the exclusion of Andhra Pradesh and Telangana from the delimitation process was arbitrary and violated Article 14 of the Constitution. The Court determined that the constitutional mandate under the third proviso to Article 170(3) acts as a bar on any readjustment of seats in state legislative assemblies until the first census conducted after the year 2026. Section 26 of the Andhra Pradesh Reorganisation Act, which provides for an increase in seats, is expressly "subject to" the provisions of Article 170. Therefore, Section 26 is not self-executing and is limited by the constitutional embargo in Article 170(3). The Court held that granting the relief sought by the petitioners would contravene this constitutional timeline, destabilize the uniform electoral framework, and open the door to similar demands from other states. Permitting such an isolated departure would also be a deviation from the principle of equality under Article 14. The Court concluded that the constitutional mandate under Article 170(3) is a bar on any delimitation exercise for the states of Andhra Pradesh and Telangana or any other state.

2. Whether the petitioners could claim parity with the delimitation exercise undertaken in the Union Territory of Jammu and Kashmir. The Court found this argument legally untenable because it overlooks the fundamental constitutional differences between states and union territories. Article 170 of the Constitution, which deals with state legislatures and contains the delimitation freeze, does not apply to union territories. The delimitation exercise in the Union Territory of Jammu and Kashmir is governed by parliamentary legislation enacted under Article 239A of the Constitution. This distinction was previously established in the case ofHaji Abdul Gani Khan & Anr. v. Union of India & Ors.. The Court therefore held that the states of Andhra Pradesh and Telangana and the Union Territory of Jammu and Kashmir operate in distinct constitutional domains, and a delimitation exercise in one cannot serve as a basis for comparison for the other.

The Court also rejected the petitioners' argument based on the doctrine of "legitimate expectation". While this doctrine is a principle of administrative law, it cannot override an express provision of the law or the Constitution. Since any expectation arising from Section 26 of the Andhra Pradesh Reorganisation Act is subject to the constitutional bar in Article 170(3), it cannot be legally sustained.

Based on these findings, the Court dismissed the writ petitions, concluding that the exclusion of Andhra Pradesh and Telangana from the delimitation process was not arbitrary or discriminatory, but rather was based on a clear and rational constitutional framework.