Previous Year Question
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 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?
Both Statement I and Statement II are correct and Statement II is the correct explanation for Statement I.
Both Statement I and Statement II are correct and Statement II is not the correct explanation for Statement I.
Statement I is correct but Statement II is incorrect.
Statement I is incorrect but Statement II is correct
Correct Answer: C
Detailed Solution
Statement I is correct
Article 16(4) enables the State to make reservations in appointments or posts in favour of any backward class of citizens which, in the State’s opinion, is not adequately represented in services under the State.
On the other hand, Article 335 provides that the claims of members of the Scheduled Castes and Scheduled Tribes shall be taken into consideration in appointments to services and posts connected with the affairs of the Union or a State, consistently with the maintenance of efficiency of administration.
Reading the reservation provisions with Article 335, the Supreme Court has held in different decisions that:
The State’s power to provide reservation is not unlimited.
Administrative efficiency must be considered along with adequate representation and social justice.
Reservation policies must conform to constitutional limitations and the broader framework of equality.
While implementing reservation, the State must ensure that the overall efficiency of administration is not improperly impaired.
In M. Nagaraj v. Union of India (2006), the Supreme Court upheld the constitutional amendments concerning reservation in promotion but required the State to observe constitutional standards such as inadequate representation and administrative efficiency.
Subsequently, in Jarnail Singh v. Lachhmi Narain Gupta (2018), the Court clarified that separate quantifiable data regarding the backwardness of Scheduled Castes and Scheduled Tribes was not required. However, inadequate representation and the requirement of administrative efficiency under Article 335 remained relevant.
Statement II is incorrect
Article 335 does not provide a definite or exhaustive definition of “efficiency of administration.”
It merely lays down the constitutional principle that the claims of Scheduled Castes and Scheduled Tribes must be considered consistently with the maintenance of administrative efficiency.
Thus:
Article 335 refers to administrative efficiency.
It does not specify its complete definition, indicators or measurement criteria.
Efficiency is assessed with reference to factors such as the nature of the post, requirements of the service, qualifying standards and administrative responsibility.
Proviso to Article 335
The Eighty-second Constitutional Amendment Act, 2000 inserted a proviso into Article 335. It permits the State to make provisions in favour of Scheduled Castes and Scheduled Tribes concerning reservation in promotion by:
Relaxing qualifying marks; or
Lowering standards of evaluation.
The Constitution thus seeks to balance social justice with administrative efficiency. Statement I is correct, but Article 335 does not define efficiency; therefore, Statement II is incorrect.