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The reasonable classification test under Article 14 requires intelligible differentia and rational nexus with object sought. Which case applied this test to uphold OBC reservation while introducing the 'creamy layer' exclusion to ensure benefits reach neediest?
- Kesavananda Bharati v. State of Kerala (1973)
- Indra Sawhney v. Union of India (1992)
- Minerva Mills v. Union of India (1980)
- SR Bommai v. Union of India (1994)
Answer: Indra Sawhney v. Union of India (1992)
Reasonable classification in reservation jurisprudence: (a) Indra Sawhney (Mandal case, 1992): 9-judge bench upheld 27% OBC reservation applying reasonable classification test: (i) Intelligible differentia: Socially and educationally backward classes distinct from forward castes based on social, educational, economic indicators, (ii) Rational nexus: Reservation aims to remedy historical disadvantage, promote substantive equality, (b) Creamy layer exclusion: (i) Rationale: Ensure benefits reach neediest within OBCs; advanced sections ('creamy layer') excluded based on income, occupation, education criteria, (ii) Proportionality: Balances affirmative action with merit; prevents reverse discrimination, (c) Subsequent evolution: (i) M. Nagaraj (2006): Reservation in promotions requires quantifiable data on backwardness, inadequacy of representation, administrative efficiency, (ii) Davinder Singh (2024): Sub-classification within SCs permitted to address intra-group inequalities, (d) Applications: (i) State-level OBC lists: States identify backward classes based on local conditions, subject to National Commission for Backward Classes scrutiny, (ii) Economic criteria: 103rd Amendment (EWS reservation) adds economic criteria for forward castes, (e) Illustrates calibrated affirmative action: Reasonable classification enables substantive equality while preventing overbreadth; empirical basis ensures reservations achieve transformative justice without undermining merit.