Hon’ble Supreme Court’s decision on SC-ST reservation in promotion
While hearing the petitions filed in the SC ST reservation case in promotion, the Hon’ble Supreme Court’s decision gave its decision. The decision will significantly establish the criteria to protect the interest of the entire society, which lies at the core of the governance system and the reservation system included in it.
The three-judge bench that heard the said petitions in the Supreme Court was headed by Justice Nageswara Rao, with Justice Sanjiv Khanna and Justice BR Gavai as members of the bench.
In this article, we will discuss the background of the reservation system in promotion, the provision of reservation system in promotion and the decisions given earlier, the challenges faced in implementing the provision and the decision given by the Hon’ble Court.
Background of reservation system in promotion
Considering the reservation system to be necessary in the promotion given in government service, in the past, the Hon’ble Supreme Court has given its decisions, which are considered to be mainly starting from the year 2006 in M. Nagaraj vs Union of India.
Here the Hon’ble Supreme Court had upheld the decision of the Parliament to extend the reservation.
Here some such criteria were set by the Hon’ble Supreme Court, which were expressed inability to fulfill by the State Governments.
Mainly three conditions are mentioned in this order, which are as follows,
1. The state has to show the backwardness of the class concerned.
2. The State will also have to state that there is inadequate representation of the class in the post/service concerned.
3. At the same time, the state will also have to say that the reservation given in promotion will protect the interests of administrative efficiency.
Provisions of reservation system in promotion and decisions given earlier
1. Indira Sahani v. Union of India – In this case, it was mainly decided that Article 16(4) recognizes reservation only in appointment and not in promotion.
2. 77th Constitutional Amendment 1995 – In this amendment, by amending the Indira Sahani case decision, by adding subsection a to Article 16(4), it was given the form of 16(4)a and ending its effect, reservation in promotion to the states But exemption was given for making law.
3. 81st Constitutional Amendment 2000 – 81st Amendment added subsection 164)b which provides that if a post remains vacant even after reservation in promotion, it can be carried forward to the next year.
4. 85th Amendment 2001 – In this amendment provision of consequential seniority was added for reservation in promotion.
Presently the judgment given by the Hon’ble Court and its background-
The matter began because of a petition filed in the High Court currently in the state of Tripura.
It was said in this petition that there has been a violation of the conditions laid down in the case of M. Nagaraj for reservation in promotion, as a result of which section 4(2) of the Tripura Scheduled Castes, Tribes (Reservation in Vacancies in Services and Posts) Act 1991 has been repealed.
In this hearing, the Division Bench of the Hon’ble Supreme Court in which Justice Kurian Joseph and Justice R Banumathi were members, decided to refer the entire matter to the Constitution Bench of the Hon’ble Supreme Court on 14 November 2017.
In this, the Constitution Bench has been given the responsibility of evaluating whether the decision of M. Nagraj case is opposing the decision of Indra Sahani case.
After this, in the hearing of September 2018, while passing the verdict, the condition of display of backwardness was canceled and also passed the principle of ‘creamy layer exclusion’. According to the principle of creamy layer exclusion, the government servants falling in the creamy layer of SC/ST category are excluded from reservation in promotion.
In compliance with the decision and conditions given in the M. Nagaraj case, the High Courts of various states quashed the proposals of the state governments regarding reservation in promotion as illegal, due to which the situation of conflict between the government and the court started in many states. Along with this, many petitions have also been filed in the Hon’ble High / Supreme Court in this regard.
The Hon’ble Supreme Court in its order on Friday, 28 January 2022 has said that,
1. States will be bound to collect data on the inadequacy of SC ST representation.
2. The responsibility of collecting this data will be entirely with the states, for which all the criteria will also have to be decided by the states, there will be no interference of the Hon’ble Supreme Court.
3. Further, the Hon’ble Supreme Court has also directed that the ‘cadre’ in respect of SC ST representation should be treated as a unit for collection of quantitative data and not the entire service of the Government servant.
4. There will be a need to collect quantitative data besides assessing the inadequacy of SC/ST representation after periodic review.
5. At the same time, the bench has made it clear that there will be no tampering with the criteria laid down in the decisions taken on the said subject in the past, they will remain the same.
Challenges and consequences in implementing the reservation system in promotion-
Since the reservation system in the Republic of India is a sensitive issue, it is a very challenging task to make it beneficial for the whole society, to make it universal and to implement it practically, which has a very challenging task in the country’s judicial and executive. There must be coordination and trust in the system.
The political importance of this issue dates back to the beginning of independent India. The impractical, anti-law, politically motivated promises made from time to time by various political parties to the public to take political advantage, make this sensitive issue mutually antagonistic in the views and facts of the government and the judiciary. Due to which sympathy for the government and dissatisfaction against the judiciary grows in the mind of the people.
At the same time, in the event of not being able to fulfill the promises full of impractical, anti-law, politically motivated political gains, there is also anger in the mind of the public towards the system.
Apart from the politicization of this issue, there are many other challenges such as it creates unnecessary dependence on reservation, which will hinder the progress of the country somewhere.
On the one hand, this system perpetuates the caste system in the society and can frustrate the class that depends on merit.
On the other hand, it can also do injustice to the rightful owner of reservation, for example, not reaching the facility of this system to the one who really needs reservation is a big challenge.
There are different ideologies on the issue of reservation in our country, keeping in mind that it should be the duty of the society, executive and judiciary to respect the basic spirit of reservation and fulfill the purpose for which the reservation system was implemented.
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Hindi Version (हिंदी संस्करण )
पदोन्नति में एससी – एसटी आरक्षण पर माननीय सर्वोच्च न्यायालय का निर्णय
पदोन्नति में एससी एसटी आरक्षण मामले में दायर याचिकाओं पर सुनवाई करते हुए माननीय सर्वोच्च न्यायालय ने अपना निर्णय सुनाया जो कि महत्वपूर्ण रूप से शासन व्यवस्था और उसमे सम्मिहित आरक्षण व्यवस्था के मूल में निहित सर्व समाज के हित की रक्षा करने के मानदंड स्थापित कर सकेगा।
सर्वोच्च न्यायालय में उक्त याचिकाओं पर सुनवाई करने वाली तीन न्यायाधीश वाली पीठ की अध्यक्षता जस्टिस नागेश्वर राव ने की, साथ ही जस्टिस संजीव खन्ना और जस्टिस बी आर गवई पीठ के सदस्य रहे।
हम इस लेख में पदोन्नति में आरक्षण व्यवस्था की पृष्ठभूमि, पदोन्नति में आरक्षण व्यवस्था के प्रावधान और पूर्व में दिए गए निर्णय, प्रावधान को लागू करने में आने वाली चुनौतियां और माननीय न्यायालय द्वारा दिए गए निर्णय पर चर्चा करेंगे।
पदोन्नति में आरक्षण व्यवस्था की पृष्ठभूमि-
आरक्षण व्यवस्था को सरकारी सेवा में दी जाने वाली पदोन्नति में आवश्यक मानते हुए पूर्व में माननीय सर्वोच्च न्यायालय ने अपने निर्णय दिए जो कि प्रमुख रूप से वर्ष 2006 में एम. नागराज बनाम भारत संघ से प्रारम्भ माना जाता है।
यहां माननीय सर्वोच्च न्यायालय ने आरक्षण में विस्तार देने के संसद के फैसले को मान्य करार दिया था।
यहां माननीय सर्वोच्च न्यायालय द्वारा कुछ ऐसी मानदण्ड तय किये गए जो कि राज्य सरकारो द्वारा पूरे किए जाने में अक्षमता जताई गई।
इस आदेश में प्रमुख रूप से तीन शर्तो का उल्लेख मिलता है जोकि निम्न प्रकार हैं,
1. राज्य को सम्बन्धित वर्ग का पिछड़ापन दिखाना होगा।
2. राज्य को यह भी बताना पड़ेगा कि सम्बन्धित पद/सेवा में वर्ग का प्रतिनिधित्व अपर्याप्त है।
3. साथ ही राज्य को यह भी बताना पड़ेगा कि पदोन्नति में दिया जाने वाला आरक्षण प्रशासनिक दक्षता के हितों की रक्षा करेगा।
पदोन्नति में आरक्षण व्यवस्था के प्रावधान और पूर्व में दिए गए निर्णय –
1. इंदिरा सहानी बनाम भारत संघ – इस मामले में मुख्य रूप से यह निर्णय आया कि अनुच्छेद 16(4) में केवल नियुक्ति में आरक्षण को मान्यता है न कि पदोन्नति में।
2. 77वां संविधान संशोधन 1995 – इस संशोधन में इंदिरा सहानी केस निर्णय में संशोधन करते हुए अनुच्छेद 16(4) में उपधारा a जोड़ कर इसे 16(4)a का रूप दिया गया और इसके प्रभाव को समाप्त करते हुए राज्यो को पदोन्नति में आरक्षण पर कानून बनाने के लिए छूट प्रादन की गई।
3. 81वां संविधान संशोधन 2000 – 81वें संशोधन में उपधारा 164)b जोड़ी गयी जो यह व्याख्या करती है कि अगर कोई पद पदोन्नति में आरक्षण के बाद भी खाली रह जाता है तो उसे अगले वर्ष के लिए आगे बढ़ाया जा सकता है।
4. 85वां संशोधन 2001 – इस संशोधन में पदोन्नति में आरक्षण के लिए पारिणामिक ज्येष्ठता का प्रावधान जोड़ा गया।
वर्तमान में माननीय न्यायालय द्वारा दिए गया निर्णय और उसकी पृष्ठभूमि-
वर्तमान में त्रिपुरा राज्य में उच्च न्यायालय में दाखिल की गई याचिका की वजह से यह मामला शुरू हुआ।
इस याचिका में कहा गया कि पदोन्नति में आरक्षण के लिए एम. नागराज मामले में निर्धारित शर्तो का उलंघन हुआ है जिसके परिणाम स्वरूप ‘त्रिपुरा अनुसूचित जाति, जनजाति (सेवाओ और पदों में रिक्तियों में आरक्षण) अधिनियम 1991 की धारा 4(2) को रद्द कर दिया गया। इस सुनवाई में माननीय सर्वोच्च न्यायालय की डिवीजन बेंच जिसमे जस्टिस कुरियन जोसेफ और जस्टिस आर भानुमति सदस्य थे, ने 14 नवम्बर 2017 को इस पूरे मामले को माननीय सर्वोच्च न्यायालय की संविधान पीठ को सौपने का निर्णय लिया।
इसमे संविधान पीठ को यह मूल्यांकन करने की जिम्मेदारी तय की गई कि क्या एम. नागराज मामले का निर्णय इंद्रा सहानी मामले के निर्णय का विरोध तो नही कर रहा है।
इसके बाद सितम्बर 2018 की सुनवाई में फैसला सुनाते हुए पिछड़ेपन के प्रदर्शन की शर्त को रद्द कर दिया और साथ ही ‘क्रीमी लेयर अपवर्जन’ का सिद्धान्त पारित कर दिया। क्रीमी लेयर अपवर्जन सिद्धान्त के अनुसार एससी एसटी वर्ग के क्रीमी लेयर में आने वाले सरकारी सेवक को पदोन्नति में आरक्षण से बाहर रखा गया है।
एम. नागराज मामले में दिए गए निर्णय और शर्तों के पालन में विभिन्न राज्यो के उच्च न्यायालय ने पदोन्नति में आरक्षण सम्बन्धी राज्य सरकारों के प्रस्तावों को विधि विरुद्ध बताते हुए रदद् कर दिया जिससे कई राज्यो में सरकार और न्यायालय के बीच टकराव की स्थिति बनने लगी। साथ ही इस सम्बंध में माननीय उच्च/सर्वोच्च न्यायालय में कई याचिका भी डाल दी गयी।
शुक्रवार, 28 जनवरी 2022 को माननीय सर्वोच्च न्यायालय ने अपने आदेश में कहा है कि,
1. राज्य एससी एसटी प्रतिनिधित्व की अपर्याप्तता पर डेटा एकत्र करने के लिए बाध्य रहेंगे।
2. इस डेटा को एकत्र करने की जिम्मेदारी पूर्ण रूप से राज्यो की रहेगी जिसके लिए सभी मानदंड भी राज्यो को ही तय करने होंगे इसमे माननीय सर्वोच्च न्यायालय का कोई दखल नही रहेगा।
3. आगे माननीय सर्वोच्च न्यायालय का यह भी निर्देश है कि एससी एसटी प्रतिनिधित्व के सम्बंध में ‘काडर’ को मात्रात्मक डेटाल के संग्रह के लिए इकाई के रूप में ही माना जाय न कि सरकारी सेवक की सम्पूर्ण सेवा को।
4. आवधिक समीक्षा के बाद एससी एसटी प्रतिनिधित्व की अपर्याप्तता के आकलन के अलावा मात्रात्मक डेटा का संग्रह करने की अनिवार्यता रहेगी।
5. साथ ही पीठ ने स्पष्ट किया है कि पूर्व में उक्त विषय पर लिए गए निर्णयों में निर्धारित मानदण्ड से कोई छेड़छाड़ नहीं कि जाएगी वो पूर्ववत ही रहेंगे।
पदोन्नति में आरक्षण व्यस्था को लागू करने में चुनौतियाँ और परिणाम- चूंकि भारत गणराज्य में आरक्षण व्यवस्था एक संवेदनशील मुद्दा है इसलिए इसे सर्व समाज के लिए हितकारी बनाना, सर्वमान्य बनाना और व्यवहारिक रूप से लागू करना बड़ा ही चुनौतीपूर्ण कार्य है जिमसें देश की न्यायिक और कार्यपालिक व्यवस्था के बीच समन्वय और भरोसा होना बेहद आवश्यक है।
इस मुद्दे का राजनीतिक महत्व आजाद भारत के प्रारम्भ से ही है। समय समय पर विभिन्न राजनीतिक दलों द्वारा जनता को किये गए अव्यहारिक, विधि विरोधी, राजनीति से प्रेरित राजनीतिक लाभ लेने की कुचेष्ठा से परिपूर्ण वादे इस संवेदनशील मुद्दे को सरकार और न्यायपालिका के विचारों और तथ्यों में पारस्परिक विरोधी बनाते हैं। जिससे जनता के मन मे सरकार के लिए सहानुभूति और न्यायपालिका के विरुद्ध असन्तोष पनपता है। साथ ही अव्यहारिक, विधि विरोधी, राजनीति से प्रेरित राजनीतिक लाभ लेने की कुचेष्ठा से परिपूर्ण वादे पूरे न कर पाने की स्थिति में व्यवस्था के प्रति भी जनता के मन मे रोष व्याप्त होता है।
इस मुद्दे के राजनीतिकरण के अलावा और भी कई चुनौती हैं जैसे आरक्षण पर गैरजरूरी निर्भरता बनाती है जोकि कहीं न कहीं देश की तरक्की में व्यवधान ही डालेगी।
एक ओर जहां यह व्यवस्था समाज में जाति व्यवस्था को कायम रखती है और उस वर्ग जो कि योग्यता पर निर्भर करता है उसे निराश कर सकती है।
वहीं दूसरी ओर आरक्षण के असली हकदार के साथ भी कहीं न कहीं अन्याय कर सकती है मसलन जिसे आरक्षण की वाकई जरूरत है उस तक इस व्यवस्था की सुविधा का नही पहुच पाना एक बड़ी चुनौती है।
हमारे देश मे आरक्षण के मुद्दे पर अलग अलग विचारधारा मौजूद हैं जिनको ध्यान में रखते हुए आरक्षण की मूल भावना का सम्मान करना और जिस उद्देश्य के लिए आरक्षण व्यवस्था लागू की गई थी उसे पूरा करना ही समाज, कार्यपालिका और न्यायपालिका का कर्तव्य होना चाहिए।
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