The Government of India constituted the Second Backward Classes Commission under Article 340 of the Constitution, chaired by B. P. Mandal. It was tasked with identifying socially and educationally backward classes and recommending measures, including possible reservations in public employment.
After nationwide data collection and analysis, the Commission submitted its report to the President of India, recommending (among other measures) 27% reservation for Other Backward Classes (OBCs) in central government services to keep total reservations within a then-accepted 50% ceiling.
Prime Minister V. P. Singh’s government moved to implement the Mandal Commission recommendations for central government services, setting the stage for an executive order reserving 27% of vacancies for socially and educationally backward classes (SEBC/OBC).
The Department of Personnel & Training issued O.M. No. 36012/31/90-Estt.(SCT) providing 27% reservation in civil posts and services under the Government of India (filled by direct recruitment) for SEBC/OBCs—an administrative trigger for nationwide protests and extensive litigation.
In early proceedings in Indra Sawhney & Ors. v. Union of India (W.P. (C) No. 930 of 1990), the Supreme Court issued an order during the first wave of challenges to the 1990 OBC reservation policy, marking the case’s formal judicial trajectory toward a constitutional-bench decision.
The Mandal implementation and protests accelerated the rise of backward-caste mobilization and reshaped party competition and coalition politics in North India, with OBC-centered parties and leaders gaining prominence in subsequent electoral cycles.
The Government issued an amended Office Memorandum dated 25 September 1991, modifying the 1990 O.M. (including providing for preference within the 27% for poorer sections of SEBCs) and adding an additional 10% reservation for certain economically backward sections not covered by existing reservations—later struck down by the Supreme Court.
A nine-judge Constitution Bench considered the validity of OBC reservations in central services and the scope of permissible criteria for identifying backward classes under Article 16(4), consolidating numerous petitions tied to the Mandal implementation.
The Supreme Court’s landmark “Mandal verdict” upheld 27% reservation for OBCs in central government employment but required exclusion of the “creamy layer,” reaffirmed a 50% overall ceiling (subject to narrow exceptions), and ruled that reservations generally should not extend to promotions (as a constitutional default).
Following Indra Sawhney, the Department of Personnel & Training issued O.M. No. 36012/22/93-Estt.(SCT) laying down criteria for excluding the socially advanced (“creamy layer”) among OBCs from reservation benefits in central services.
With the Court’s conditions and the 1993 exclusion guidelines in place, the central OBC reservation regime moved from contested executive policy to a more stable, court-shaped administrative framework (including non-inclusion of the creamy layer and application rules for direct recruitment).
In later proceedings connected to the Mandal litigation, the Supreme Court noted substantial time had passed since the 16 November 1992 judgment and addressed non-compliance issues, reflecting continued judicial supervision over implementation of its directions.
Reservation policy debates and implementation: the Mandal Commission era (1979–1992)
