Article 335 of the Costitution of India with Case law
Here is a comprehensive explanation of Article 335 of the Constitution of India, along with relevant case law:
📜 Article 335 – Constitution of India
“Claims of Scheduled Castes and Scheduled Tribes to services and posts”
✅ Text of Article 335 (as amended):
"The claims of the members of the Scheduled Castes and the Scheduled Tribes shall be taken into consideration, consistently with the maintenance of efficiency of administration, in the making of appointments to services and posts in connection with the affairs of the Union or of a State:
Provided that nothing in this article shall prevent in making any provision in favour of the members of the SCs and STs for relaxation in qualifying marks in any examination or lowering the standards of evaluation, for reservation in matters of promotion to any class or classes of services or posts in connection with the affairs of the Union or of a State."
🧾 Key Features of Article 335:
| Aspect | Description |
|---|---|
| Objective | To balance reservation benefits for SC/STs with the need for administrative efficiency |
| Scope | Applies to appointments and promotions in Union and State services |
| Amendment | Modified by the 82nd Constitutional Amendment Act, 2000, allowing relaxation of marks |
| Efficiency Clause | Any reservation must be consistent with maintaining efficiency of administration |
| Promotion Relaxation | Allows for relaxation of qualifying marks and standards in promotions for SC/STs |
⚖️ Important Case Laws on Article 335:
1. Indra Sawhney v. Union of India (1992)
Citation: AIR 1993 SC 477
Issue: Validity of reservations in promotions.
Held: Article 335 implies that efficiency of administration cannot be compromised excessively for the sake of reservation.
Relevance: Promotion quotas were struck down for OBCs, though SC/ST promotions were permitted under certain limitations.
2. M. Nagaraj v. Union of India (2006)
Citation: (2006) 8 SCC 212
Issue: Validity of constitutional amendments allowing SC/ST reservations in promotions (Articles 16(4A) and 16(4B)).
Held:
Article 335 requires that administrative efficiency be maintained.
The State must provide quantifiable data on backwardness, inadequate representation, and impact on efficiency before granting promotions under reservation.
Relevance: Article 335 acts as a balancing mechanism — reservation must not come at the cost of efficiency.
3. Jarnail Singh v. Lachhmi Narain Gupta (2018)
Citation: (2018) 10 SCC 396
Held:
Reiterated the importance of efficiency in administration (Article 335).
“Creamy layer” exclusion applicable to SC/STs in promotions as well.
Relevance: Builds upon M. Nagaraj, enforcing data-based approach and protecting administrative efficiency.
4. State of Punjab v. Salil Sabhlok (2013)
Citation: (2013) 5 SCC 1
Issue: Political appointments and efficiency in administration.
Held: Efficiency of administration is paramount, and appointments should reflect merit and competence.
Relevance: Reinforces the principle of Article 335 in appointments and public administration.
📚 Summary Table:
| Feature | Description |
|---|---|
| Purpose | Ensure SC/ST representation in government services |
| Efficiency Clause | Reservation must not undermine the effectiveness of administration |
| Promotion Clause (Post-2000) | Allows relaxation of marks/standards in promotions for SC/STs |
| Court Stance | Supported, but subject to conditions like data, representation, and efficiency |
| Key Amendments | 82nd Amendment (2000): Relaxation allowed in qualifying standards |
🧠 Why Article 335 Matters:
It provides constitutional legitimacy to affirmative action for SCs and STs.
Balances social justice with administrative competence.
Acts as a check on overuse or unregulated reservation policies.
Guides policy and judicial decisions on promotion and recruitment in public employment.
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