The Mandal Commission Case, Indra Sawhney & Ors. V. Unioin of India & Ors.

The landmark judgment in Indra Sawhney v. Union of India (1992), popularly known as the Mandal Commission Case, remains one of the most significant constitutional rulings in India's history on affirmative action and equality. Delivered by a nine-judge bench with a 6:3 majority, the decision upheld the constitutionality of 27% reservation for Other Backward Classes (OBCs) in public employment while establishing critical limitations to ensure balance between equality and social justice. The Court recognized caste as a valid but not exclusive determinant of social and educational backwardness, clarified that Article 16(4) is a facet—not an exception—of Article 16(1), and introduced key doctrines that continue to shape reservation policy. Among these were the 50% ceiling on total reservations, the exclusion of the ‘creamy layer' from benefits, and the restriction of reservations in promotions—later modified by the 77th Constitutional Amendment (1995). The dissenting opinions reflected contrasting constitutional philosophies, emphasizing either broader social justice or strict merit-based equality. The ruling's long-term significance lies in its balanced approach: legitimizing OBC reservations while embedding principles of fairness, rationality, and administrative efficiency. Despite ongoing debates over caste-based policies, meritocracy, and the rigidity of the 50% cap, Indra Sawhney remains the cornerstone of India's reservation jurisprudence—defining the contours of affirmative action and guiding the nation's pursuit of substantive equality in a stratified society.