Sr Advocate Sanjay Hegde makes his submissions in brief.

Hegde: SCs necessarily means that everybody has suffered the taint of untouchability. How untouchable, thats a different thing , there were some people who were merely not seeable , there were some people who were not touchable, some who's money can be touched. Now all of those were put into one class by the constitution of India in the constitutional lot in the presidential order called SCs ... there are several judgements of this court which say that what distinguishes the SCs from other classes is the taint of untouchability.

Hegde : Once there was a taint of untouchability, how untouchable were you ? the constitution and the makers that time decided not to go into that question. They form one homogenous class , and that homogenous class they said that you could possibly include or exclude through parliamentary enactment but in no manner, therefore a court could not add or subtract, neither executive, nor state tinker in any manner..that is the basis of Chinnaiah