M. Nagaraj and Ors. v Union of India and Ors.
Rule established
Constitutional amendments enabling reservation in promotions for SC/ST (77th, 81st, 82nd, 85th Amendments) are valid, but the state must satisfy three conditions: (a) backwardness of the class, (b) inadequate representation, and (c) no adverse effect on overall administrative efficiency.
Facts
- Following Indra Sawhney (1992), which held that Art.16(4) reservation could not extend to promotions, Parliament enacted the 77th, 81st, 82nd, and 85th Amendments inserting Articles 16(4A) and 16(4B)
- These amendments were challenged as violating the basic structure, particularly the equality code under Articles 14, 15, and 16
Issue
- Whether the constitutional amendments enabling reservation in promotions for SC/ST candidates are valid, and if so, what conditions must govern their application.
Held
- The Court upheld the validity of the amendments; they do not violate the basic structure since they merely enable (not mandate) reservation in promotion
- Before providing reservation in promotion, the state must collect quantifiable data demonstrating:
- (a) Backwardness of the class
- (b) Inadequate representation in the relevant cadre or service
- (c) Reservation would not affect overall efficiency of administration (Art.335)
Ratio Decidendi
Constitutional amendments enabling reservation in promotions for SC/ST candidates are valid and do not violate the basic structure, but their actual application by the state is conditioned on demonstrable backwardness, inadequate representation, and preservation of administrative efficiency, alongside continued adherence to the 50 percent ceiling and creamy layer exclusion.
How to use it in an exam
- Part A: Connects reservation in promotion to the pre-existing Indra Sawhney framework.
- Part B: Enabling provisions are not blank cheques; the state must independently justify each reservation-in-promotion measure with quantifiable data.
- Later development: Jarnail Singh v Lachhmi Narain Gupta (2018) clarified that quantifiable data on backwardness of SC/STs is not required (only inadequate representation and efficiency).
Source
Source: (2006) 8 SCC 212; landmark decision upholding constitutional amendments on promotion reservation with conditions
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.