UPSC Prelims 2023 Q40: Article 335 and Efficiency of Administration
Consider the following statements:
Statement-I:
The Supreme Court of India has held in some judgements that the reservation policies made under Article 16(4) of the Constitution of India would be limited by Article 335 for maintenance of efficiency of administration.
Statement-II:
Article 335 of the Constitution of India defines the term 'efficiency of administration'.
Which one of the following is correct in respect of the above statements?
- Both Statement-I and Statement-II are correct and Statement-II is the correct explanation for Statement-I
- Both Statement-I and Statement-II are correct and Statement-II is not the correct explanation for Statement-I
- Statement-I is correct but Statement-II is incorrect
- Statement-I is incorrect but Statement-II is correct
Answer: (c) Statement-I is correct but Statement-II is incorrect
Statement-wise explanation
- Statement-I: correct — Article 335 says the claims of SCs and STs to posts must be considered 'consistently with the maintenance of efficiency of administration'. In M. Nagaraj (2006), a five-judge bench upheld Article 16(4A) and the 82nd Amendment. It held that a State giving reservation in promotion must show backwardness, inadequate representation and that overall administrative efficiency under Article 335 is maintained. Jarnail Singh (2018) and Jarnail Singh (28 January 2022) kept the Article 335 requirement. Indra Sawhney (1992) also read Article 335 as a limit on reservation under Article 16(4).
- Statement-II: incorrect — Article 335 uses the phrase 'efficiency of administration' but does not define it. The Supreme Court said this directly in B.K. Pavitra II (10 May 2019): the Article does not define what the framers meant by the phrase. The Court then read it in an inclusive sense, so that efficiency includes diverse sections of society being represented. Because Statement-II is false, it cannot explain Statement-I.
How to eliminate
Start with Statement-II, because you can test it from the bare text. Constitutional articles rarely define broad administrative ideas such as 'efficiency', 'public order' or 'morality'. Definitions sit in Article 366 or in specific definition clauses, not in a directive-style article like Article 335. Article 335 is a single sentence plus a proviso about relaxing qualifying marks. It has no definition clause. Once Statement-II is false, two options drop out: the two that say both statements are correct. One more drops out with them: the option saying Statement-I is incorrect but Statement-II is correct. That leaves one choice, provided you accept Statement-I. Statement-I is safe from basic knowledge: the words 'consistently with the maintenance of efficiency of administration' are the best-known part of Article 335, and the Nagaraj conditions (backwardness, inadequacy of representation, administrative efficiency) are standard Polity content. The fact to remember: Article 335 uses 'efficiency of administration' but never defines it, and the Supreme Court said so in B.K. Pavitra II (2019).
Know more
Article 335 and reservation in promotion
Article 335 sits in Part XVI (Special Provisions relating to Certain Classes). It has two parts:
- Main clause: SC/ST claims to Union and State posts must be considered consistently with the maintenance of efficiency of administration.
- Proviso (82nd Amendment, 2000): the State may relax qualifying marks or lower evaluation standards for SCs/STs in matters of reservation in promotion.
The proviso reversed S. Vinod Kumar (1996). That ruling had struck down lower qualifying marks in promotion as against Article 335.
How the courts used Article 335
| Case | Year | What it held |
|---|---|---|
| Indra Sawhney | 1992 | Article 16(4) does not allow reservation in promotion. Article 335 limits reservation, and some posts (e.g. technical, specialised) may be kept out of it. |
| M. Nagaraj | 2006 | Upheld Articles 16(4A), 16(4B) and the 82nd Amendment proviso. Before reserving in promotion, the State must show backwardness, inadequate representation and overall administrative efficiency. |
| Jarnail Singh | 2018 | Dropped the need for data on SC/ST backwardness. Applied the creamy layer to SCs/STs in promotion. |
| B.K. Pavitra II | 2019 | Noted that 'efficiency of administration' is not defined. Read it inclusively: representation of diverse groups is part of efficiency. |
| Jarnail Singh | 2022 | Three-judge bench. Data on inadequate representation must be collected cadre-wise. The Court set no yardstick for 'adequacy'. |
Related amendments
- 77th (1995): inserted Article 16(4A), allowing reservation in promotion for SCs/STs.
- 81st (2000): inserted Article 16(4B), allowing unfilled reserved vacancies to be carried forward without counting towards the 50% ceiling.
- 85th (2001): added 'with consequential seniority' to Article 16(4A).
Pattern to remember: Article 16(4) and 16(4A) give the power to reserve. Article 335 is the limit the courts check that power against.
In the news
The Supreme Court's three-judge bench ruled on reservation in promotion in Jarnail Singh on 28 January 2022, the year before this paper. That ruling restated the Nagaraj conditions, including administrative efficiency under Article 335, and reopened debate on how states must collect data. The question itself tests the static text of Article 335.
NCERT Concepts to Revise
- Claims of SCs and STs to services: This is Article 335 itself. Both statements turn on what its text says about efficiency of administration.
- 82nd Constitutional Amendment Act 2000: The 82nd Amendment added Article 335's proviso. Check whether that proviso defines anything or only allows relaxations.
- Reservation in promotion: Statement-I is about how courts limited reservation in promotion, the area where Article 335 matters most.
- M. Nagaraj case: Nagaraj is the leading case linking reservation in promotion under Article 16 to administrative efficiency under Article 335.
- Jarnail Singh case: Jarnail Singh (2018, 2022) revisited the Nagaraj conditions, including the Article 335 efficiency requirement.
- Reservation in public employment: Article 16(4) gives the State its power to reserve public jobs. Statement-I asks what limits that power.