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Supreme Court of India 2022-01-28 disposed

Jarnail Singh & Ors vs Lachhmi Narain Gupta & Ors

Bench: 3 — L. Nageswara Rao, Sanjiv Khanna, B.R. Gavai

In Brief

This judgment addresses six critical issues concerning reservation in promotions for Scheduled Castes and Scheduled Tribes under Article 16(4-A) of the Constitution. The Court held that while States have discretion to grant such reservation, they must justify it with quantifiable data showing inadequacy of representation in the specific cadre (not the entire service or group). The Court declined to prescribe a fixed yardstick for measuring adequacy, leaving this to State discretion based on local conditions. It clarified that 'cadre' is the correct unit for collecting representation data and rejected collecting data on a group basis. The Court also held that M. Nagaraj's principles apply prospectively from the date of that judgment to avoid disruption. The judgment overruled B.K. Pavitra II's approval of group-based data collection, emphasizing cadre-specific collection is required.

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Constitutional Law Reservation Scheduled Castes and Scheduled Tribes Public Employment Promotions Adequate Representation Cadre Quantifiable Data

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