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R.R. Inamdar v. The State of Karnataka & Ors.

Civil Appeal · 2019 INSC 1298Decided 28 Nov 2019
Civil Appeal No. 1495 of 2016
Dr. Justice D.Y. Chandrachud · Justice Ajay Rastogi

Background

The appellant, a Scheduled Caste candidate and school teacher, was promoted in 2002 to the sole post of Lecturer in English at a Karnataka school under reservation rules. A senior, non-reserved-category teacher (the fifth respondent) challenged this, arguing that since there was only one such post, it could not legally be filled through reservation. After years of departmental appeals, the Karnataka High Court (both a Single Judge and a Division Bench on appeal) ruled in the senior teacher's favour, relying on earlier Supreme Court precedent holding that a solitary, non-interchangeable post cannot be reserved. The appellant then appealed to the Supreme Court.

Decision Breakdown

The Supreme Court upheld the well-established constitutional principle, drawn from a Constitution Bench ruling and reaffirmed in several later cases, that reservation under Article 16(4) requires a plurality of interchangeable posts within a cadre; a single, non-interchangeable post in one discipline (here, the sole Lecturer-in-English post at one school) cannot be reserved, since doing so would effectively create 100% reservation for that post, contrary to Article 16(1). The Court rejected the appellant's argument that a 1991 government circular requiring roster maintenance "unit-wise" changed this analysis, holding that a circular cannot override binding constitutional case law. However, recognising that the appellant had worked in the post in good faith since 2002 under a court-protected status quo, the Court crafted a practical remedy: it directed the State of Karnataka to consider creating an additional (or, if needed, a supernumerary) post for the appellant within two months, ordered that no recovery of salary be made from her for her past service, and directed that the senior respondent's pay and retirement benefits be fixed notionally from her due date of appointment (without back-pay for the period she did not actually work), while also directing her prompt consideration for promotion.

Lesson Learnt

Reservation in public employment can only be applied where there is more than one interchangeable post in a cadre, a solitary post in a particular role cannot be reserved, however well-intentioned the appointment, but courts can still soften the real-world impact on an individual who relied in good faith on an earlier appointment, for instance by directing creation of an additional post rather than simply removing them.

Official source (sci.gov.in)View Judgment (PDF)

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