ROHTAS BHANKHAR vs U.O.I.

The Supreme Court held that the provisions for relaxed qualifying standards for Scheduled Castes and Scheduled Tribes candidates in departmental examinations, as per the 1970 Office Memorandum, were rendered legally invalid by the amendment of the 1964 Regulations and the judgment in S. Vinod Kumar v. Union of India (1996). The Court found that the earlier ruling in S. Vinod Kumar did not consider Article 16(4A) and thus was per incuriam. The Court upheld the validity of the amendment allowing for relaxation in qualifying marks under the newly added proviso to Article 335 of the Constitution, thereby permitting such provisions for Scheduled Castes and Scheduled Tribes candidates.