VidhiSangh

Supreme Court of India · 28/01/2022

JARNAIL SINGH & ORS versus LACHHMI NARAIN GUPTA & ORS

[2022] 19 S.C.R. 711 · 2022 INSC 105

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Summary

Answering common questions in promotion-reservation litigation, the Court required cadre-specific quantifiable data on inadequate SC/ST representation and periodic review at reasonable intervals fixed by government. It declined to prescribe a uniform adequacy yardstick or population-proportion test. M. Nagaraj was declared prospective to avoid unsettling longstanding promotions. The approval of group-wise data in B.K. Pavitra II was held contrary to binding precedent; individual cases remained for hearing.

Issues

  1. What unit and criteria govern data on inadequate representation for reservation in promotion.
  2. Whether a fixed review period or population-proportion formula should be prescribed.
  3. Whether M. Nagaraj operates prospectively and group-wise data approved in B.K. Pavitra II accords with precedent.

Provisions considered

Held

Result

Common issues answered; individual merits left open and matters listed for further hearing on 24 February 2022.

Judgment PDF: Supreme Court of India, [2022] 19 S.C.R. 711.