Q100.Consider the following statements:
Statement-I: The Supreme Court of India has held in some judgements that the reservation policies made under Article 16(4) of the Constitution of India would be limited by Article 335 for maintenance of efficiency of administration.
Statement-II: Article 335 of the Constitution of India defines the term ‘efficiency of administration’.
Which one of the following is correct in respect of the above statements?
a. Both Statement-I and Statement-II are correct and Statement-II is the correct explanation for Statement-I
b. Both Statement-I and Statement-II are correct and Statement-II is not the correct explanation for Statement-I
c. Statement-I is correct but Statement-II is incorrect
d. Statement-I is incorrect but Statement-II is correct
Question from UPSC Prelims 2023 GS Paper
Explanation :
c. Statement-I is correct but Statement-II is incorrect
Supreme Court Judgments on Reservation Policies
The Supreme Court of India has held in some judgments that the reservation policies made under Article 16(4) of the Constitution of India would be limited by Article 335 for the maintenance of efficiency of administration. This means that while providing reservation to certain groups, the efficiency of administration should not be compromised.
N.M. Thomas vs. State of Kerala (1976): The Supreme Court upheld the state government’s decision to extend reservation to SC and ST candidates in promotional posts. The court argued that such reservations were a way to ensure equality of opportunity, stating that Article 335 should not be interpreted in a manner that undermines the purpose of Article 16(4).
Indra Sawhney vs. Union of India (1992): Often referred to as the Mandal Commission case, this judgment declared that reservations could be valid but should not exceed 50% of the available positions, considering it essential to maintain an efficient administration as mandated by Article 335. The court also stated that the concept of ‘efficiency’ is not merely numerical but should be understood as an overall efficiency including the representation of backward classes.
M. Nagaraj & Others vs. Union of India & Others (2006): This case re-affirmed that reservations in promotions can be constitutionally valid but should be applied cautiously, with the state needing to show quantifiable data to justify such reservations. The court ruled that any reservation policy should not disturb the efficiency of administration, reiterating the balance mandated by Article 335.
Article 335 of the Constitution of India
Article 335 of the Constitution of India does not define the term ‘efficiency of administration.’ Article 335 states that the claims 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.
