Consider the following statements: Statement-I: The Supreme Court of India has held in some judgements that the reservation policies made under Article 16(4) of the Constitution of India would be limited by Article 335 for maintenance of efficiency of the administration. Statement-II: Article 335 of the Constitution of India defines the term 'efficiency of administration'. Which one of the following is correct in respect of the above statements?
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- ABoth Statements-I and Statement-II are correct and Statement-II is the correct explanation for Statement-I
- BBoth Statement-I and Statement-II are correct and Statement-II is not the correct explanation for Statement-I
- CStatement-I is correct but Statement-II is incorrect
- DStatement-I is incorrect but Statement-II is correct
Show answer
Answer: (C) Statement-I is correct but Statement-II is incorrect
Statement-I is correct:
The Supreme Court has ruled (in Indra Sawhney 1993, M. Nagaraj 2006) that reservation policies under Article 16(4) are limited by Article 335, which requires maintaining 'efficiency of administration.'
Statement-II is wrong:
Article 335 does NOT define the term 'efficiency of administration.'
So Statement-I is correct but Statement-II is not.
Answer is (c).
Article 335 requires maintaining 'efficiency of administration' in reservations but deliberately does not define what this means, leaving it to executive and judicial interpretation.
The Supreme Court's M. Nagaraj judgment (2006) became highly relevant around 2022-23 when multiple states sought to breach the 50% reservation ceiling, making this constitutional balance a live issue.
Article 16(4) Reservation Policies
Indian Polity Article 16(4) reservation policies
Article 16(4): Reservation in Public Employment & Constitutional Limits
Article 16(4) enables state to make reservations for backward classes in public services
Supreme Court has ruled that Article 335 limits Article 16(4) reservations
Reservation cannot compromise efficiency of administration
Indra Sawhney (1993) and M. Nagaraj (2006) are landmark cases on this balance
Constitutional Framework
Article 16 guarantees equality of opportunity in public employment. While Article 16(1) provides the general right, Article 16(4) creates an exception allowing states to make reservations for 'backward classes' who are not adequately represented in services.
• Article 16(4): 'Nothing in this article shall prevent the State from making any provision for the reservation of appointments or posts in favour of any backward class of citizens which, in the opinion of the State, is not adequately represented in the services under the State'
• This provision enables affirmative action in government jobs
• It covers reservations for SCs, STs, and OBCs
Key Supreme Court Judgments
Case | Year | Key Ruling on Reservations |
|---|---|---|
Indra Sawhney (Mandal Case) | 1993 | Article 16(4) reservations limited by Article 335 - efficiency cannot be compromised |
M. Nagaraj | 2006 | Reaffirmed that reservation must not affect efficiency of administration |
Jarnail Singh | 2018 | Struck down creamy layer exclusion for SC/ST promotions but upheld efficiency test |
Question Context
The PYQ tests whether students know that Supreme Court has consistently held Article 16(4) reservations are constitutionally limited by Article 335's efficiency requirement. This judicial interpretation balances social justice with administrative effectiveness.
Trap: Students may think Article 16(4) gives unlimited power to make reservations - but Supreme Court has imposed limits
Trap: Don't confuse Article 16(4) with Article 15(4) which deals with educational reservations
Trap: Indra Sawhney is often tested - remember it limited reservations, not expanded them
Article 335 & Administrative Efficiency
Indian Polity Article 335 efficiency of administration
Article 335: Claims of SCs/STs vs Administrative Efficiency
Article 335 requires considering SC/ST claims consistent with administrative efficiency
Article 335 does NOT define what 'efficiency of administration' means
Supreme Court interprets this as a constitutional limitation on reservations
Creates balance between social justice and administrative competence
Article 335 Text
Article 335 states: 'The claims of the members of the Scheduled Castes and the Scheduled Tribes shall be taken into consideration, consistently with the maintenance of efficiency of the administration, in the making of appointments to services and posts in connection with the affairs of the Union or of a State'.
Key phrase: 'consistently with the maintenance of efficiency' - this creates the constitutional balance.
Constitutional Interpretation
Article 335 mentions 'efficiency of administration' but provides no definition of what this means
Supreme Court has developed this concept through judicial interpretation in various cases
'Efficiency' includes competence, merit, performance standards, and administrative effectiveness
This creates a constitutional ceiling - reservations cannot cross the efficiency threshold
The balance varies case-by-case based on nature of post and administrative requirements
Question Analysis
Statement-II in the PYQ incorrectly claims Article 335 defines efficiency of administration. This is the key trap - Article 335 only mentions this concept but leaves its definition to judicial interpretation and administrative discretion.
Major Trap: Article 335 mentions efficiency but does NOT define it - this distinction is frequently tested
Trap: Don't assume 'efficiency' has a fixed constitutional definition - it's developed through case law
Trap: Article 335 applies specifically to SC/ST appointments, not all reservation categories
Reservation vs Efficiency Doctrine
Indian Polity maintenance of efficiency reservation policies
Constitutional Balance: Social Justice vs Administrative Efficiency
Constitution requires balancing reservation policies with administrative needs
Indra Sawhney established the efficiency-reservation balance doctrine
Courts can strike down reservations that compromise efficiency
Different standards apply to different types of government posts
Judicial Doctrine
The Supreme Court has developed a constitutional doctrine that reservations under Article 16(4) cannot be absolute. They must be balanced against the requirement in Article 335 to maintain administrative efficiency. This creates a judicially reviewable standard for reservation policies.
Efficiency Standards by Post Type
Type of Post | Efficiency Considerations | Reservation Impact |
|---|---|---|
Technical/Specialized | High competency requirements | Stricter efficiency standards |
Administrative | General management skills | Moderate efficiency standards |
Clerical/Support | Basic qualification sufficient | More flexible on reservations |
Promotions | Performance-based advancement | Efficiency vs seniority balance |
Practical Applications
Qualifying marks: Cannot be lowered below minimum competency for reserved candidates
Promotion quotas: Must consider performance and efficiency alongside reservation claims
Specialized services: Higher efficiency standards for technical posts like engineering, medical
Creamy layer: Economic exclusion within OBC to maintain both equity and efficiency
Roster system: Ensures systematic implementation without compromising standards
Trap: Efficiency is not anti-reservation - it's a constitutional requirement to balance social justice
Trap: Courts don't define efficiency in absolute terms - it varies by context and post requirements
Trap: This doctrine applies to all reservation types under Article 16(4), not just SC/ST
Statement-Based Question Technique
Indian Polity Statement-I Statement-II
Mastering Statement-Explanation Questions in Constitutional Law
Each statement must be evaluated independently first, then for logical connection
Definitional claims are often traps - check if Constitution actually defines the term
Supreme Court interpretations vs constitutional text are different things
Statement Analysis Method
%%{init: {"flowchart": {"wrappingWidth": 460}}}%%
flowchart TD
s1["`**Check Statement-I**
Is this **factually correct**? Does Supreme Court actually say this?`"]
s2["`**Check Statement-II**
Is this **factually correct**? Does Constitution actually define/state this?`"]
s3["`**Check Logical Link**
IF both true, does Statement-II **explain WHY** Statement-I is correct?`"]
s4["`**Match Options**
Find option matching your analysis: both true + explanation, both true + no explanation, one true, etc.`"]
s1 --> s2
s2 --> s3
s3 --> s4This Question's Pattern
Statement-I makes a judicial interpretation claim (Supreme Court has held...) while Statement-II makes a constitutional text claim (Article 335 defines...). The trap is that students might assume if courts use a term, the Constitution must define it. Wrong - courts often interpret undefined constitutional terms.
Major Trap: 'Constitution defines X' vs 'Constitution mentions X' - very different things
Trap: Supreme Court using a term doesn't mean Constitution defines that term
Trap: Don't assume logical connection exists just because both statements are individually true