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1. ISSUES PRESENTED and CONSIDERED
The core legal questions considered in this judgment are: (i) Whether a seat can be earmarked in the Legislature of a State for a representative of a group of religious institutions after its complete merger in India. (ii) Whether seats can be reserved in favor of a particular tribe far in excess of its population. (iii) Whether the provisions for reservation of seats in the Legislative Assembly of Sikkim for Bhutias-Lepchas and Sanghas are unconstitutional as they violate the basic features of democracy and secularism under the Indian Constitution. (iv) Whether the reservation of seats is violative of Articles 14, 15, 325, and 332 of the Constitution. (v) Whether the reservation of seats for Bhutias-Lepchas is ultra vires of clause (f) of Article 371-F. (vi) Whether the reservation of a seat for Sangha, based on religious distinctions, is unconstitutional. 2. ISSUE-WISE DETAILED ANALYSIS (i) Relevant legal framework and precedents: The judgment discusses the historical context of Sikkim's merger with India and the constitutional amendments made to accommodate the unique demographic and political situation of Sikkim. Article 371-F, introduced by the Constitution (Thirty-Sixth Amendment) Act, 1975, provides special provisions for Sikkim. (ii) Court's interpretation and reasoning: The Court examined whether the impugned provisions violated the basic structure of the Constitution, particularly the principles of democracy and secularism. It considered the historical context, the need to protect minority interests, and the unique political situation of Sikkim. (iii) Key evidence and findings: The Court noted the historical agreements and legislative provisions that led to the current reservation system in Sikkim. It emphasized the need to balance representation for different ethnic groups to maintain social stability. (iv) Application of law to facts: The Court applied the principles of constitutional interpretation to determine whether the reservations were justified under Article 371-F and whether they violated fundamental constitutional principles. (v) Treatment of competing arguments: The Court considered arguments regarding the violation of the "one person, one vote" principle and the potential impact on secularism. It also addressed the historical necessity of the reservations to protect minority interests in Sikkim. (vi) Conclusions: The Court concluded that the reservation of seats for Bhutias-Lepchas was justified given the historical context and the need to protect minority interests. However, it found the reservation of a seat for Sangha, based on religious considerations, to be unconstitutional. 3. SIGNIFICANT HOLDINGS The Court held that while the reservation of seats for Bhutias-Lepchas was permissible under Article 371-F, the reservation of a seat for Sangha was unconstitutional as it violated Articles 15(1) and 325 of the Constitution. Core principles established include the recognition of historical and demographic factors in determining the validity of special provisions for newly admitted states, while ensuring that such provisions do not violate the basic features of the Constitution. Final determinations on each issue: - The reservation of seats for Bhutias-Lepchas was upheld as constitutionally valid. - The reservation of a seat for Sangha was struck down as unconstitutional.
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