On 19 September 1975, a seven-judge Bench of the Supreme Court upheld a Kerala rule temporarily exempting Scheduled Caste and Scheduled Tribe employees from a departmental promotion test — and, in the reasoning that mattered far beyond that rule, held that Article 16(4) is not an exception carved out of Article 16(1) but an emphatic restatement of the equality guarantee itself. The 5:2 disposition supplied the substantive-equality reading that *Indra Sawhney* would later build the modern reservations framework upon.