Issues

Is Article 329A (4) of the Constitution valid?

Are the Representation of People’s (Amendment) Act, 1974, and the Election Laws (Amendment)

Act, 1975 constitutionally valid?

Is Indira Gandhi’s election valid?

Judgment

The Supreme Court ruled that Article 329A was unconstitutional, violating the basic structure doctrine established in the Kesavananda Bharati case. It stated that the principles of free and fair elections are fundamental and cannot be amended by Parliament.

While the court upheld the validity of the 1974 and 1975 amendments, affirming Parliament's authority to regulate elections, it emphasized the judiciary's critical role in protecting democratic principles. Ultimately, the court found insufficient evidence against Indira Gandhi regarding electoral malpractice, declaring her election valid and allowing her to continue as Prime Minister.

Facts:

In this case, the Supreme Court of India addressed crucial issues surrounding reservation policies in public service appointments, particularly focusing on the "carry forward rule" and its constitutional implications. T. Devadasan, a member of a Scheduled Caste, applied for a position in Indian Railways after successfully passing the relevant examinations. As part of the Government of India's policy to reserve a proportion of public employment for Scheduled Castes and Scheduled Tribes to uplift these communities, Devadasan was eligible for appointment.

However, he was denied the position because it was filled by another candidate from a Scheduled Caste under the reservation policy. Devadasan contended that this decision violated his fundamental right to equality as enshrined in Article 14 of the Constitution of India, which mandates equality before the law and equal protection of the laws. He argued that the reservation policy represented reverse discrimination, depriving him of employment opportunities for which he was fully qualified.

The case prompted the Supreme Court to examine questions of equality, discrimination, and the legality of the reservation policy in employment.

Issues:

1. Is the Carry Forward Rule, which allows unfilled reserved positions to be carried over, in violation of Article 16(1) of the Constitution?

2. Does Article 16(4), permitting reservations for backward classes, infringe upon Articles 16(1) and 14?

Judgment:

The Supreme Court delivered a majority ruling (4:1) against the Carry Forward Rule, declaring it unconstitutional. The Court found that the rule led to excessive reservations, reaching as high as 65%, which was deemed unreasonable. It clarified that while Article 16(4) is an exception to Article 16(1), its application must not compromise the principle of equal opportunity enshrined in Article 14. The Court emphasized that reservations should not exceed 50% to maintain a balance between affirmative action and equal opportunity.

The judgment asserted that affirmative action must not result in reverse discrimination against those not in reserved categories, as this would infringe upon the rights of others. The Court reiterated that no individual should face discrimination in public employment based on caste and that merit-based appointments should be prioritized. Furthermore, it called for periodic reviews of reservation policies to ensure they do not undermine the rights of other candidates.

The ruling established essential guidelines for future recruitment processes, ensuring adherence to constitutional mandates and preventing disproportionate reservations, thus maintaining the principle of equal opportunity for all candidates in public service appointments.