M. Nagaraj v. Union of India
M. Nagaraj v. Union of India (2006) held that 77th, 81st, 82nd, and 85th Amendments are constitutionally valid
Citation: (2006) 8 SCC 212
Case at a Glance
Summary
This five-judge Constitution Bench upheld the constitutional validity of the 77th, 81st, 82nd, and 85th Amendments providing for reservation in promotions for SCs/STs, consequential seniority, and carry-forward of unfilled vacancies. However, the Court imposed conditions requiring the State to demonstrate backwardness, inadequate representation, and maintenance of administrative efficiency before implementing reservation in promotions. The judgment balanced equality of opportunity with protective discrimination, holding that these conditions are enabling provisions requiring data-based justification. This case significantly shaped the law on reservation in promotions.