Landmark Cases on Reservation in India
Landmark Cases on Reservation in India
1. M.R. Balaji vs. State of Mysore (1963)
Issue: Whether the reservation for backward classes can exceed 50% of available seats.
Ruling: The Supreme Court held that reservation cannot exceed 50% to maintain the principle of equality under Article 14.
Significance: Set the “50% ceiling” on reservations in India (with some later exceptions).
2. Indra Sawhney vs. Union of India (1992) (The Mandal Case)
Issue: Validity of the 27% reservation for Other Backward Classes (OBCs).
Ruling: The Supreme Court upheld the 27% reservation for OBCs but introduced the “creamy layer” concept, excluding the socially advanced among OBCs from reservation benefits.
The Court reaffirmed the 50% ceiling but allowed exceeding it in exceptional cases.
Significance: Major judgment that clarified and shaped the policy on OBC reservations; introduced creamy layer exclusion.
3. State of Kerala vs. N.M. Thomas (1976)
Issue: Whether reservation in promotions is valid.
Ruling: The Supreme Court upheld reservations in promotions for Scheduled Castes (SCs) and Scheduled Tribes (STs).
It ruled that Article 16(4) allows reservation in promotions.
Significance: Validated affirmative action beyond initial recruitment.
4. Ashok Kumar Thakur vs. Union of India (2008)
Issue: Validity of the reservation for OBCs in central educational institutions under the Central Educational Institutions (Reservation in Admission) Act, 2006.
Ruling: Upheld OBC reservation but reinforced the creamy layer exclusion and emphasized the 50% limit.
Significance: Confirmed reservation in higher education institutions and emphasized socio-economic criteria.
5. Jarnail Singh vs. Lachhmi Narain Gupta (2018)
Issue: Whether reservation in promotions is allowed.
Ruling: Overturned the State of Kerala vs. N.M. Thomas decision, ruling that reservation in promotions is not protected under Article 16(4).
This judgment limited reservations in promotions.
6. Saurabh Chaudhari vs. Union of India (2021)
Issue: Validity of state-level reservations exceeding the 50% cap.
Ruling: The Supreme Court allowed states to provide reservation exceeding 50% in some circumstances.
Significance: This case has opened the possibility of reservations beyond the traditional 50% limit in states.
Summary
| Case | Year | Key Outcome |
|---|---|---|
| M.R. Balaji vs. State of Mysore | 1963 | Set 50% reservation ceiling |
| Indra Sawhney vs. Union of India | 1992 | Upheld OBC reservation; introduced creamy layer |
| State of Kerala vs. N.M. Thomas | 1976 | Allowed reservation in promotions |
| Ashok Kumar Thakur vs. UOI | 2008 | Upheld OBC reservation in education; creamy layer |
| Jarnail Singh vs. L.N. Gupta | 2018 | Overturned reservation in promotions |
| Saurabh Chaudhari vs. UOI | 2021 | Allowed >50% reservation in exceptional cases |
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