In the Jarnail Singh vs. Lachhmi Narain Gupta case (2018), a 5-judge bench of the Supreme Court modified the earlier M. Nagaraj (2006) framework regarding reservation in promotions. Which of the following parameters was completely removed as a mandatory pre-requisite for the State to show?

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In M. Nagaraj (2006), the Supreme Court laid down three mandatory criteria for reservation in promotions for SCs/STs: backwardness, inadequacy of representation, and overall administrative efficiency (Article 335). In Jarnail Singh (2018), the 5-judge bench held that requiring quantifiable data for backwardness contradicts the explicit text of the landmark 9-judge Indra Sawhney judgment, which presumed backwardness for SCs and STs. Hence, that specific condition was removed, although inadequacy of representation and efficiency criteria remain mandatory.

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