The Indra Sawhney & Others v. Union of India is a landmark constitutional judgment delivered by the Supreme Court on November 16, 1992, often called the Mandal Commission Case. Its origin lies in the challenge to the V.P. Singh government's decision to implement the Mandal Commission recommendations, which provided 27% reservation for Socially and Educationally Backward Classes (SEBCs), or Other Backward Classes (OBCs), in central government jobs. The problem it solved was establishing a definitive legal framework for reservation policy under Article 16(4) of the Constitution.
The judgment, delivered by a 6:3 majority of a nine-judge bench, upheld the 27% reservation for OBCs but introduced three key provisions. First, it established the 50% Ceiling Rule, holding that total reservation under Article 16(4) must ordinarily not exceed 50% to maintain the balance of equality of opportunity. Second, it mandated the exclusion of the "creamy layer"—the socially and economically advanced persons among the OBCs—from reservation benefits. Third, the Court ruled that reservation would apply only to initial appointments and not to promotions.
The judgment connects directly to Article 16(4), which permits the state to make provisions for the reservation of appointments or posts in favour of any backward class of citizens. The prohibition on reservation in promotions was later circumvented by the 77th Constitutional Amendment Act of 1995, which inserted Article 16(4A), allowing for reservation in promotion for Scheduled Castes and Scheduled Tribes. More recently, the 50% ceiling was effectively pierced by the 103rd Amendment Act of 2019, which introduced a 10% quota for Economically Weaker Sections (EWS) under Articles 15(6) and 16(6). The Supreme Court upheld the EWS quota in Janhit Abhiyan v. Union of India (2022), ruling that the 50% limit applies only to reservations for socially and educationally backward classes, not to the new EWS category.