Educational Qualification: A valid ground for classification in Reservation

Recently Supreme Court in the case of Chandan Banerjee & Ors v. Krishna Prosad Ghosh & Ors held that educational qualification is a valid ground for classification between persons of the same class in matters of promotion. The 3 judge bench comprising of Justice DY Chandrachud, Vikram Nath and Hima Kohli also held that classification which is based on educational qualification is not violative of Article 14 and the Article 16 of the Constitution of India.

Justice Chandrachud went on further stating that legislature must be given adequate opportunity to decide the quality of individuals in matters of public policy and public employment. The honorable bench has relied on the judgement given in the case of State of Jammu Kashmir v.Trilokinath Khosa , where in it was held that classification on the basis of educational qualification is valid as it was linked with enhancing administrative efficiency in any organisation.

It is pertinent to know that various principals have emerged out of this judgement. Firstly, to bear a nexus with the efficiency required in promotional posts, an institution can differentiate on the basis of educational qualification for the purpose of promotion and same shall not be considered violative of Article 14 and 16. Secondly, In matters concerning whether a classification is reasonable or not, the scope of judicial review is limited as courts cannot deep dive into mathematical evaluation in the matters of promotion.