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In M. Nagaraj v. Union of India (2006), the Supreme Court upheld reservation in promotions for SCs/STs but imposed three conditions. Which of the following was NOT one of these conditions?
- Collect quantifiable data showing backwardness of class
- Prove inadequacy of representation in particular post
- Maintain overall administrative efficiency
- Exclude creamy layer from reservation benefits
Answer: Exclude creamy layer from reservation benefits
Reservation in promotions conditions: (a) M. Nagaraj (2006): Upheld constitutional amendments (77th, 81st, 82nd, 85th) enabling reservation in promotions for SCs/STs but imposed three conditions: (i) Collect quantifiable data showing backwardness of class, (ii) Prove inadequacy of representation in particular post, (iii) Maintain overall administrative efficiency, (b) NOT condition: Exclude creamy layer — this was added later in Jarnail Singh (2018), which applied creamy layer exclusion to SC/ST promotions, (c) Rationale for conditions: (i) Quantifiable data: Ensures reservation based on empirical evidence of disadvantage, not presumption, (ii) Inadequacy of representation: Reservation justified only where SCs/STs underrepresented in particular posts, (iii) Administrative efficiency: Reservation should not compromise merit, efficiency in public services, (d) Applications: (i) State implementation: States conduct studies, collect data on SC/ST representation in promotions, (ii) Judicial review: Courts examine whether conditions met before upholding reservation in promotions, (e) Evolution: Jarnail Singh (2018) added creamy layer exclusion to Nagaraj conditions, further calibrating reservation in promotions, (f) Illustrates calibrated affirmative action: Balancing group justice with individual merit, administrative efficiency; empirical basis ensures reservations achieve transformative justice without undermining efficiency.