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Reservation in Promotion: Revisiting M. Nagraj and Indra sawhney With the insertion of Article 16(4-A), the 77th constitutional amendment in 1995. A completely new debate has been authored whether the person once gets the benefit of reservation again entitled for it?  The said Article is reproduced here as follows : Article 16 (4A) :  Nothing in this article shall prevent the State from making any provision for reservation in matters of promotion, with consequential seniority, to any class or classes of posts in the services under the State in favour of the Scheduled Castes and the Scheduled Tribes which, in the opinion of the State, are not adequately represented in the services under the State. The rationale behind the reservation under Article 16 (Equality of opportunity in matters of public employment) was that a certain group of individuals were seen as downgraded people by the upper strata of the society, so by introducing reservation they would able ...