M. Nagaraj and Others v. Union of India (2007)

Case Summary

Background:

The case of M. Nagaraj and Others v. Union of India (2007) is a landmark legal proceeding concerning the reservation policy in promotions for Scheduled Castes (SCs) and Scheduled Tribes (STs) in public employment in India. The petitioners challenged the constitutional validity of Article 16(4-A) of the Constitution, which provided for reservations in promotions for SCs and STs, contending that it violated the equality principle enshrined in Article 14 of the Constitution.

Judgment:

In its judgment delivered in 2006, the Supreme Court of India upheld the constitutional validity of Article 16(4-A) of the Constitution, affirming the reservation policy for promotions for SCs and STs in public employment. However, the court introduced certain conditions to be met by the state while implementing such reservations. These conditions include the collection of quantifiable data to establish backwardness, inadequacy of representation, and compliance with the overall efficiency of administration. The court also ruled that the "creamy layer" principle, which excludes affluent members of SCs and STs from reservation benefits, must be applied in promotions as well.

Impact:

The judgment in M. Nagaraj and Others v. Union of India (2007) had significant implications for the reservation policy in promotions for SCs and STs and the broader issue of affirmative action in India. It reinforced the constitutional validity of reservations as a means to address historical injustices and promote social equality. However, the introduction of conditions such as the need for quantifiable data and compliance with efficiency standards imposed practical challenges on the implementation of reservation policies. The judgment also emphasized the importance of balancing the interests of different social groups while ensuring the overall efficiency of administration.

List of Linked Cases:

Indra Sawhney v. Union of India (1992)

Ashoka Kumar Thakur v. Union of India (2008)

State of Kerala v. N.M. Thomas (1976)

R. Chitralekha v. State of Mysore (1964)

Balaji v. State of Mysore (1963)

Devadasan v. Union of India (1964)