Indra Sawhney Case — Amendments

Amendment	Year	Description	Impact
77th Amendment	1995	Added Article 16(4A) to enable reservation in promotions for SCs and STs, partially overruling the Indra Sawhney judgment's exclusion of promotional reservations.	Modified the Sawhney framework by allowing promotional reservations for SCs/STs while maintaining the general principle of merit-based promotions for other categories.
81st Amendment	2000	Added Article 16(4B) allowing unfilled reserved posts to be carried forward to subsequent years, ensuring reserved positions are not converted to general category.	Strengthened the reservation framework by preventing the dilution of reserved quotas through administrative delays or non-availability of suitable candidates.
85th Amendment	2001	Modified Article 16(4A) to provide consequential seniority in promotions for SCs and STs, further departing from the Sawhney principle of merit-based advancement.	Enhanced the effectiveness of promotional reservations by ensuring that reserved category promotees are not disadvantaged in subsequent career progression.