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In Indra Sawhney case (1992), the Supreme Court laid down 50% ceiling on total reservation, but held this ceiling can be exceeded in extraordinary situations reflecting ______ of a particular State or region.
- economic prosperity
- extraordinary backwardness
- political pressure
- administrative convenience
Answer: extraordinary backwardness
50% ceiling and exceptions: (a) Indra Sawhney (1992): Laid down 50% ceiling on total reservation (SC/ST/OBC combined) to balance affirmative action with merit, efficiency, (b) Exception for extraordinary situations: Ceiling can be exceeded in extraordinary situations reflecting extraordinary backwardness of a particular State/region, (c) Applications: (i) State-specific reservations: Tamil Nadu (69% reservation) protected under Ninth Schedule (though subject to basic structure review), (ii) 103rd Amendment (EWS): Added 10% reservation for EWS among forward castes, taking total reservation above 50% in some States; upheld in Janhit Abhiyan (2022) as extraordinary situation, (iii) Judicial scrutiny: Exceeding 50% ceiling subject to strict scrutiny; State must demonstrate extraordinary backwardness, compelling reasons, (d) Proportionality overlay: (i) Legitimate aim: Remedying extraordinary disadvantage, promoting substantive equality, (ii) Rational connection: Higher reservation suitable to achieve aim in extraordinary situations, (iii) Necessity: No less restrictive alternative to achieve same aim, (iv) Balancing: Affirmative action benefits vs. merit considerations; exceeding 50% requires compelling justification, (e) Illustrates calibrated affirmative action: 50% ceiling as general rule with narrow exception for extraordinary situations; proportionality ensures reservations achieve transformative justice without undermining merit.