On 26 September 2018, a five-judge Constitution Bench held that the creamy-layer principle applies to reservation in promotion for Scheduled Castes and Scheduled Tribes — and read down the requirement, articulated in M. Nagaraj (2006), that States collect quantifiable data to demonstrate backwardness of SC/STs as a condition for providing such reservation. The unanimous judgment of Justice Nariman recalibrates the doctrinal architecture between Indra Sawhney, M. Nagaraj, and the SC/ST promotion reservation regime. A digest of the question, the holding, the doctrinal logic, and the lineage.
On 19 October 2006, a five-judge Constitution Bench upheld the constitutional validity of the 77th, 81st, 82nd and 85th Amendments — which together had inserted Articles 16(4A) and 16(4B) to provide for reservation in promotion for SC/ST and the carry-forward of unfilled reserved positions. The disposition articulated the three-pronged test that has governed promotion-reservation policy ever since: backwardness, inadequacy of representation, and administrative efficiency. A digest of the holding, the three-prong architecture, and the relationship with the *Indra Sawhney* and *Jarnail Singh* lines.