Article 16(4) reservations vs Article 335 efficiency — UPSC Prelims PYQ 2023

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’.

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-1
Statement-I is correct but Statement-II is incorrect
Statement-I is incorrect but Statement-II is correct

The Supreme Court of India has consistently referred to the notions of “efficiency” and “merit,” while adjudicating the validity of various reservation policies.
The Court has held in several judgments — Indra Sawhney v Union of India 1993; M Nagaraj v Union of India 2006 — that the reservation policies made under Article 16(4) of the Constitution would be limited by Article 335, which provides for “maintenance of efficiency of administration,” while considering the claims of the Scheduled Castes (SCs) and the Scheduled Tribes (STs) in the making of appointments to public services and posts. This was done while the Constitution does not define the term “efficiency of administration.”This gap in interpretation was filled by a two-judge bench in the B K Pavitra (II) v Union of India (2019), as it held that “efficiency of administration in the affairs of the union or of a state must be defined in an inclusive sense, where diverse segments of society find representation as a true aspiration of governance by and for the people.”

Statement II can be easily identified as wrong because the Constitution often mentions concepts without clearly defining them. Article 335 refers to “efficiency of administration” but does not define it. Hence, Statement II is incorrect, making option (c) the correct answer.

Article 16 prohibits discrimination against matters of public employment or appointment on the grounds of race, religion, caste, sex, place of birth, descent, or residence.
It provides special provisions for backward classes in matters of public employment or appointment.
Article 16(4) allows the State to make reservations in appointments or posts in favour of any backward class of citizens.
Article 16(4A) was inserted by the 77th Constitutional Amendment Act, 1995. It provides for the reservation of promotions in public employment for SCs and STs.
Article 16(4B) was inserted by the 81st Constitutional Amendment Act, 2000. It allows the State to carry over the unfilled vacancies reserved for SCs and STs to subsequent years. It is referred to as the “carry forward rule”.