Concept Page

Indra Sawhney Judgment (1992)

The *Indra Sawhney Judgment (1992)* is a landmark Supreme Court ruling that upheld the 27% reservation for Other Backward Classes (OBCs) in government jobs while capping total quotas at 50%. It reinforced the principle of *creamy layer* exclusion to ensure benefits reach the most disadvantaged. For example, it struck down the Mandal Commission’s initial 27% recommendation until socioeconomic criteria were refined.

Indira Sawhney v. Union of India (1992) stands as the Supreme Court’s definitive pronouncement on affirmative action in India, crystallising the constitutional balance between formal equality and substantive redress for historically disadvantaged groups. Rendered on 16 November 1992 by a nine‑judge bench headed by Chief Justice M. N. Venkatachaliah, the judgment upheld a 27 percent reservation for Other Backward Classes (OBCs) in central government jobs while imposing a hard ceiling of 50 percent on the aggregate of all reservations. Its most enduring legacy is the articulation of the “creamy‑layer” doctrine, which bars OBC candidates whose family income exceeds a statutory threshold from benefitting from the quota.

Historical Background

The case emerged from the implementation of the Mandal Commission’s 1980 report, which recommended a 27 percent reservation for OBCs based on social, educational and economic criteria. In 1990, the Union of India issued a notification extending the OBC quota to central services, prompting Indira Sawhney, a Scheduled‑Caste aspirant, to file a writ petition challenging the constitutional validity of the measure. The petition invoked Articles 14, 15, 16 and 335 of the Constitution, arguing that the reservation violated the principle of equality and the merit‑based selection envisaged by Article 16(1). The bench, comprising Justices S. R. Bhat, K. S. Puttaswamy (then‑Chief Justice), A. M. Ahmadi, M. N. Venkatachaliah, J. S. Verma, M. K. Mukherjea, S. P. Singh, M. M. S. S. M. K. B. R. S. R. K. S. R. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S. S.

    Indra Sawhney Judgment (1992) — UPSC Concept | TheKnowledgeOrbits