Jarnail Singh v. Lachhmi Narain Gupta

This case arose from the M. Nagaraj judgment's requirement that SC/ST communities must demonstrate 'backwardness' for availing reservation in promotions. The question was whether this requirement was constitutionally valid given that SCs/STs are already presumed backward. The Constitution Bench held that the State is not required to collect quantifiable data to demonstrate backwardness of SC/STs for the purpose of providing reservation in promotions. It modified M. Nagaraj to this extent while maintaining the requirements of inadequate representation and efficiency. The judgment recognized the distinct constitutional status of SCs/STs based on untouchability and historical discrimination, distinguishing them from OBCs who are identified based on social and educational backwardness. It also applied the creamy layer concept to SC/STs in promotions.