A five-judge Constitution Bench struck down a Governor's notification reserving 100% of teacher posts in Scheduled Areas for Scheduled Tribes. The Court held the measure arbitrary, in breach of the 50% ceiling from Indra Sawhney, and beyond the Governor's Fifth Schedule power, which cannot override the fundamental rights in Part III.
On 16 November 1992, a nine-judge Constitution Bench upheld the implementation of the Mandal Commission's recommendation for 27% reservation in Central Government services for Other Backward Classes — but bounded the framework with two structural constraints: reservations could not, in the aggregate, exceed 50% of available positions, and the 'creamy layer' of the backward class had to be excluded from the benefit. Three decades on, the framework remains the constitutional architecture of Indian reservations policy. A digest of the holding, the doctrinal architecture, and how it continues to govern.