Implementation of Reservations in Andhra Pradesh: A Comprehensive Analysis of Vertical, Horizontal, and Promotional Reservations

Part I: Understanding Reservation

1.1 What Is Reservation and Why Does It Exist?

When India became a republic in 1950, the framers of the Constitution recognised that merely guaranteeing equality on paper would not be enough for communities that had been historically denied access to opportunity. A person who has been running a race in shackles cannot compete fairly even after the shackles are removed, unless they are also given a head start.

The Constitution accordingly carved out two kinds of special provisions:

• Vertical Reservations: These are the reservations most people know — for Scheduled Castes (SC), Scheduled Tribes (ST), Other Backward Classes (OBC/BC), and now Economically Weaker Sections (EWS). They operate vertically, meaning they cut across the entire selection process as a separate column. They are grounded in Articles 15(4), 16(4), 16(4A), and 16(4B) of the Constitution.

• Horizontal Reservations: These are special reservations that operate across the vertical columns — for women, persons with disabilities, ex-servicemen, and meritorious sportspersons. They are grounded in Articles 15(3) and 16(1) of the Constitution. Think of them as a net cast across all the vertical categories simultaneously.

The difference, as we shall see, is profound in its practical effect.

1.2 A Simple Illustration

Imagine a government exam for 100 posts. The State has reserved:

• 15 posts for SC candidates

• 6 posts for ST candidates

• 29 posts for BC candidates (spread across Groups A, B, C, D, E)

• 10 posts for EWS candidates

• 40 posts for Open Competition (merit-based)

This is vertical reservation — separate columns for separate communities.

Now, across ALL these 100 posts, the State also requires:

• At least 33⅓ posts (approximately 33 to 34) to go to women

• 4 posts to go to persons with benchmark disabilities

• 2 posts to go to ex-servicemen

• 2 posts to go to meritorious sportspersons

This is horizontal reservation — it cuts across all the vertical columns.

A woman SC candidate who wins a post on SC merit counts toward BOTH the SC quota AND the women's quota. This interlocking is the heart of horizontal reservation law.

Part II: Constitutional and Statutory Framework — For the Lawyer

2.1 Constitutional Provisions

The legal architecture of reservation rests on the following constitutional provisions:

The Rights of Persons with Disabilities Act, 2016 (Central Act 49 of 2016), specifically Sections 20 and 34, mandates 4% reservation in appointments and promotions in every Government establishment for persons with benchmark disabilities.

2.2 The AP State and Subordinate Service Rules, 1996

Rule 22 of the Andhra Pradesh State and Subordinate Service Rules, 1996 (G.O.Ms.No.436, GA(Ser.D), dated 15.10.1996) is the primary operative provision governing the reservation roster in Andhra Pradesh. G.O.Ms.No.77 amends Rule 22 comprehensively, inserting Rule 22-B as the new operational framework for horizontal reservations and a fresh 100-point roster for both direct recruitment and promotions.

Part III: The Roster Point System

3.1 What Is a Roster?

A roster is a running sequential register maintained by every recruiting authority. It assigns each successive vacancy a number from 1 to 100 (and then again from 101 to 200, and so on in cycles), and each number corresponds to a specific reservation category. The roster ensures that over a series of recruitments, each community receives its proportionate share of posts in a fair and transparent manner.

The roster does not create the reservation. The reservation percentages are determined by law (Rules and Government Orders). The roster merely operationalises them by translating percentages into specific vacancy numbers.

As the Supreme Court held in R.K. Sabharwal v. State of Punjab (AIR 1995 SC 1371), the roster operates as a "running account" — meaning it continues from where the last recruitment left off, rather than restarting at Point 1 for each recruitment. Once a quota for a category is filled (i.e., all the posts earmarked for that category in the 100-point cycle are filled), the roster ceases to apply for that category.

3.2 The Pre-2023 Roster in Andhra Pradesh

Prior to G.O.Ms.No.77, the AP roster under Rule 22 was deeply problematic because it mixed horizontal and vertical categories in the same roster. For example:

• Roster Points 13 and 37 were earmarked for ex-servicemen (with one preferably for women ex-servicemen).

• Roster Points 6, 31, 56 (and later 86) were earmarked for persons with disabilities.

• Roster Points 48 and 98 were earmarked for meritorious sportspersons.

This meant that when a horizontal category post fell vacant and the candidate was not available, the State faced confusion about whether to carry the vacancy forward (as it did with vertical categories) or let it lapse. It also caused the mathematical proportion of horizontal reservation to depend on where the vacancy fell in the roster, rather than on the actual composition of those selected — which is contrary to the Supreme Court's consistent direction.

3.3 The Post-2023 Roster Under G.O.Ms.No.77

The 100-point direct recruitment roster under G.O.Ms.No.77 contains ONLY vertical categories. A representative excerpt is as follows:

No roster point is assigned to women, ex-servicemen, persons with benchmark disabilities, or meritorious sportspersons. Their representation is assessed after the vertical roster is applied — in a separate third step.

The promotion roster contains only Open Competition, SC, and ST points — no BC, EWS, ex-servicemen, or sportsperson points, because these categories have no reservation in promotions.

3.4 Illustration of the New Roster in Operation

Scenario: Department X undertakes recruitment for 10 posts. The last recruitment ended at roster point 30. The new recruitment begins at point 31.

The recruiting authority checks points 31 to 40 in the vertical roster and fills:

• Point 31 (OC), 34 (OC), 35 (BC-B), 36 (OC), 37 (OC), 38 (OC), 39 (BC-D), 40 (OC) — 8 vacancies in vertical roster

• Points 32 (EWS) and 33 (ST) — 2 more vacancies

After filling all 10 by merit within each category, the department then assesses: How many of the 10 selected are women? Does the total reach 33⅓%? This is the horizontal step.

Part IV: Vertical vs. Horizontal Reservation — The Crucial Distinction

4.1 The Defining Principle

The distinction between vertical and horizontal reservation was definitively stated by the Supreme Court in Rajesh Kumar Daria v. Rajasthan Public Service Commission (2007) 8 SCC 785, and is now codified in Rule 22-B of the AP State and Subordinate Service Rules as amended by G.O.Ms.No.77:

"Social reservations in favour of SC, ST and OBC under Article 16(4) of the Constitution of India are 'vertical reservations'. Special reservations in favour of physically handicapped, women etc., under Articles 16(1) or 15(3) are 'horizontal reservations'."

4.2 How Vertical Reservation Works

Under vertical reservation, a reserved category candidate who secures a post on open merit does not exhaust the quota reserved for their community.

Illustration: Suppose the SC quota is 15% of 100 posts = 15 posts. If, on a pure merit ranking, 18 SC candidates score high enough to enter the Open Competition (OC) list of 50, those 18 SC candidates are shown as OC selections. The 15 SC reserved posts remain fully available for the next 15 SC candidates in merit order, over and above the 18 already selected in OC.

This is the rule that SC/ST communities fought hard for in courts, and it was settled definitively in Indra Sawhney v. Union of India (AIR 1993 SC 477).

4.3 How Horizontal Reservation Works

Under horizontal reservation, the principle is exactly opposite. A woman (or disabled person) who enters a post through her vertical category on merit is counted toward the women's quota. The women's quota is not something extra — it is embedded within the vertical categories.

Illustration (from G.O.Ms.No.77):

• 15 posts are reserved for SC. Of these, 5 (33⅓%) must go to SC Women.

• Step 1: List the top 15 SC candidates by merit — say, the list has 3 women and 12 men.

• Step 2: The women's quota is 5 but only 3 are in the list → shortfall of 2.

• Step 3: Take the next 2 SC women in merit order from those not yet selected, and delete 2 SC men from the bottom of the 15-candidate list.

• Final list: 15 SC candidates, of which 5 are women.

Conversely, if the merit-based list of 15 SC candidates naturally contains 7 women (more than the required 5), all 7 continue in the list. The excess women are not removed.

This principle was affirmed by the Supreme Court in PSC Uttaranchal v. Mamta Bisht (2010) 12 SCC 204:

"Thus, women selected on merit within the vertical reservation quota will be counted against the horizontal reservation for women."

4.4 The Three-Step Process (G.O.Ms.No.77, Rule 22-B(2))

G.O.Ms.No.77 formalises the three-step process for every recruitment:

Step 1 — Open Competition (Merit)
Fill all OC quota posts strictly on merit. Any SC/ST/BC/EWS candidate who is meritorious enough for the OC list is placed there; their community quotas remain intact.

Step 2 — Vertical (Social) Reservations
Fill all SC, ST, BC (Groups A–E), and EWS posts from the remaining candidates in merit order within each category, using the 100-point roster.

Step 3 — Horizontal (Special) Reservations
Examine the total list (Steps 1 + 2) to check:

• Are 33⅓% of all selected candidates women?

• Are 4% persons with benchmark disabilities?

• Are 2% ex-servicemen?

• Are 2% meritorious sportspersons?

If any quota is short, induct the next eligible candidate from that horizontal category (in merit order) by deleting an equal number from the bottom of the relevant vertical category list.

4.5 Compartmentalised vs. Overall Horizontal Reservation

In Anil Kumar Gupta v. State of U.P. (1995) 5 SCC 173, the Supreme Court distinguished two types of horizontal reservation:

• Overall Horizontal Reservation: The horizontal quota (say, women) is met by counting women selected across all vertical categories together. If the total women count across OC + SC + ST + BC + EWS equals or exceeds 33⅓%, the quota is satisfied regardless of how they are distributed among categories.

• Compartmentalised Horizontal Reservation: The horizontal quota is verified separately within each vertical category. For example, 33⅓% of the SC quota must be SC women; 33⅓% of the ST quota must be ST women; 33⅓% of the OC quota must be OC women — and so on, independently.

Andhra Pradesh follows the compartmentalised model, meaning the 33⅓% women's quota is checked and enforced within each vertical category (OC, SC, ST, BC-A, BC-B, BC-C, BC-D, BC-E, EWS, PBD, Ex-servicemen, and Sportspersons) — not in one aggregate pool.

Part V: Backlog Vacancies and the Carry-Forward Rule

5.1 What Are Backlog Vacancies?

When a recruitment round closes without filling a reserved post — because no suitable candidate from the reserved category was available — that unfilled reserved post becomes a backlog vacancy. It represents a debt owed by the State to the reserved community.

Example: In Year 1, 5 posts are reserved for ST candidates. Only 3 suitable ST candidates apply. 2 posts go unfilled. These 2 posts are "backlog ST vacancies."

5.2 The Carry-Forward Rule Explained

The carry-forward rule allows unfilled reserved vacancies to be rolled over to the next recruitment year and treated as reserved vacancies in addition to the fresh reserved vacancies arising in that year.

The legal journey of the carry-forward rule:

• T. Devadasan v. Union of India (AIR 1964 SC 179): The Supreme Court struck down the carry-forward rule in that case because it had allowed backlog carry-forwards to push SC/ST reservation to 64% in a single year — well beyond the 50% constitutional limit.

• Arati Ray Chaudhary v. Union of India (AIR 1974 SC 532): The Court held that a revised carry-forward rule (capping the combined total at 45%) was valid. Each year of recruitment must be considered separately, but a reserved vacancy may legitimately carry forward over two successive years.

• Col. A.S. Iyer v. V. Balasubramanyam (AIR 1980 SC 452): The Court confirmed that carry-forward may not exceed three successive years. After three years, if the vacancy remains unfilled, it may be dereserved.

• State of Punjab v. G.S. Gill (AIR 1997 SC 2324): The Court held carry-forward constitutionally permissible as an extension of the mandate of adequate representation under Article 335, subject to the 50% ceiling per recruitment year.

• Article 16(4B) (inserted by the 81st Constitutional Amendment, 2000): Resolved the 50% ceiling issue definitively by providing that unfilled reserved vacancies of a year shall be treated as a separate class of vacancies and shall not be counted together with current year's vacancies for the purpose of applying the 50% ceiling.

5.3 The 50% Ceiling Rule

Even after Article 16(4B), the total of reserved vacancies in any single recruitment cycle — comprising current-year reserved vacancies plus carried-forward backlog vacancies — cannot exceed 50% of the total vacancies being filled in that cycle (T. Devadasan principle, as moderated by Indra Sawhney and Article 16(4B)).

Illustration of carry-forward:

5.4 No Carry-Forward for Horizontal Reservations

In Jitender Kumar Singh v. State of U.P. (AIR 2010 SC 1851), the Supreme Court held that the carry-forward rule is applicable only to vertical (social) reservations and does not apply to horizontal (special) reservations.

G.O.Ms.No.77 codifies this principle explicitly:

• If no eligible ex-serviceman is available, the 2% reservation lapses for that recruitment — it does not carry forward.

• If no eligible meritorious sportsperson is available, the 2% reservation similarly lapses.

• For persons with benchmark disabilities (PBD), a limited form of block carry-over within the 100-point PBD register is allowed (explained in Part VII below), but this is distinct from the inter-year carry-forward applicable to SC/ST.

Part VI: Reservation in Promotions

6.1 The Constitutional Journey

The question of whether reservation could extend to promotions has been one of the most contested issues in Indian constitutional law:

1992 — Indra Sawhney v. Union of India (AIR 1993 SC 477): The nine-judge Constitution Bench held that Article 16(4), as it then stood, did not permit reservation in promotions. The Court's reasoning was that "posts" in Article 16(4) referred to initial appointments, not promotions.

1995 — 77th Constitutional Amendment: Parliament inserted Article 16(4A), enabling the State to make provision for reservation in promotions for SC/ST employees if the State is of the opinion that they are not adequately represented in the services under the State.

2000 — 81st Constitutional Amendment: Parliament inserted Article 16(4B) to clarify that unfilled reserved vacancies from promotions would not count against the 50% ceiling.

2001 — 85th Constitutional Amendment: Inserted the concept of "consequential seniority" — meaning an SC/ST employee promoted under reservation shall count their seniority from the date of such promotion, giving them seniority over general candidates promoted later.

2006 — M. Nagaraj v. Union of India (AIR 2007 SC 71): The Supreme Court upheld Articles 16(4A) and 16(4B) as constitutionally valid but imposed conditions: the State must have quantifiable data showing:

1. Backwardness of the class (though this was later modified for SC/ST);

2. Inadequacy of representation in the post(s) concerned; and

3. Overall administrative efficiency must not be compromised (Article 335).

2018 — Jarnail Singh v. Lachhmi Narain Gupta (AIR 2018 SC 4729): The Supreme Court held that SC and ST employees do not need to separately establish "backwardness" (they are constitutionally presumed backward), but the State must still collect quantifiable data showing inadequacy of representation before providing reservation in promotions.

6.2 Who Gets Reservation in Promotions?

6.3 Special Protection for PBD Employees in Service

Section 20(3) of the Rights of Persons with Disabilities Act, 2016 provides that no promotion shall be denied to a person merely on the ground of disability. Section 20(4) further provides that if an employee acquires a disability during service and is found unsuitable for the existing post, the Government must shift them to another post with the same pay scale. If adjustment is not possible, the employee is kept on a supernumerary post until a suitable post becomes available or until superannuation — whichever is earlier.

G.O.Ms.No.77 operationalises this: where a supernumerary post holder becomes eligible for promotion, a fresh supernumerary post is created at the higher level (with prior Finance Department approval) and the lower-level supernumerary post is surrendered.

Part VII: G.O.Ms.No.77 — Detailed Implementation

7.1 Genesis and Background

G.O.Ms.No.77 was issued in the backdrop of two significant developments:

1. Judicial direction: The Supreme Court, in three successive judgments (Anil Kumar Gupta 1995; Rajesh Kumar Daria 2007; Mamta Bisht 2010), had clearly laid down the correct method of implementing horizontal reservations. The AP Government's earlier practice — assigning fixed roster points to horizontal categories — was inconsistent with this law.

2. Committee Report: The Government constituted an inter-departmental committee chaired by the Principal Secretary, Social Welfare Department (G.O.Ms.No.121, dated 12.10.2022) to study the issue. The Committee recommended, among other things, that no roster point be earmarked for horizontal categories and that horizontal verification occur at the end of every 100-point vertical cycle.

The Government accepted these recommendations and issued G.O.Ms.No.77 under the proviso to Article 309 of the Constitution.

7.2 Key Changes Made by G.O.Ms.No.77

Change 1: Deletion of All Horizontal Roster Points

The old roster points for ex-servicemen (RP 13, 37), PBDs (RP 6, 31, 56, 86), and sportspersons (RP 48, 98) are all deleted. The new 100-point direct recruitment roster contains only vertical categories (OC, SC, ST, BC-A through E, EWS). No horizontal category appears in the direct recruitment roster.

Change 2: New 100-Point Direct Recruitment Roster

The revised roster reflects the following percentage distribution:

Change 3: Expanded PBD Definition

The term "Physically Handicapped Persons" is replaced throughout the Rules with "Persons with Benchmark Disabilities (PBD)." The definition is expanded from 3 to 5 sub-categories in line with the Rights of Persons with Disabilities Act, 2016:

• (a) Blindness and Low Vision

• (b) Deaf and Hard of Hearing

• (c) Locomotor Disability (including cerebral palsy, leprosy cured, dwarfism, acid attack victims, muscular dystrophy)

• (d) Autism, Intellectual Disability, Specific Learning Disability, Mental Illness

• (e) Multiple Disabilities including deaf-blindness

Change 4: PBD Reservation Increased to 4%

The PBD reservation in both appointments and promotions is increased from 3% to 4%, with 1% each for four categories (categories (a)–(d); category (e) is included within the four but filled from any available sub-category).

Change 5: Dedicated PBD Reservation Register

Each administrative department must maintain a separate 100-point PBD Reservation Register (distinct from the main vertical roster). This register has 100 points divided into four blocks of 25:

• Block 1: Points 1–25 (Priority point: Point 1)

• Block 2: Points 26–50 (Priority point: Point 26)

• Block 3: Points 51–75 (Priority point: Point 51)

• Block 4: Points 76–100 (Priority point: Point 76)

Points 1, 26, 51, and 76 are earmarked for four disability sub-categories respectively. The first available vacancy in each block is filled by the relevant PBD sub-category. If no suitable vacancy exists in Block 1, two PBD vacancies are filled from Block 2; if Block 2 also yields nothing, three are filled from Block 3, and so on. This is the block carry-over mechanism unique to PBDs.

Change 6: No Roster Points for Women, Ex-Servicemen, Sportspersons

Rule 22-A is amended to add Sub-Rule (5) explicitly providing: "Roster Points shall not be assigned for Horizontal reservations for Women." Similarly, no roster points are assigned for ex-servicemen or sportspersons.

Change 7: Women's Horizontal Reservation — 33⅓% in Three Cycles

For PBD, ex-servicemen, and sportsperson categories (which are small quotas), women's 33⅓% horizontal reservation is assessed after completion of three complete cycles of 100 points each (i.e., after 300 points), not after every 100 points.

Change 8: Promotion Roster Simplified

The 100-point promotion roster now contains only OC, SC, and ST points. EWS, BC, ex-servicemen, sportsperson, and PBD-specific roster points are absent from the promotion roster — consistent with the law that only SC, ST, and PBD employees have reservation in promotions.

7.3 Illustration: Full Three-Step Process in Action

Scenario: A Department recruits for 30 posts. Vertical roster distribution for 30 posts:

• OC: 12 posts

• SC: 4 posts

• ST: 2 posts

• BC (all groups): 8 posts

• EWS: 3 posts

• Remaining: 1 post (OC)

Total selected candidates: 30

Step 1 — Fill OC on merit: Top 12 merit rankers (regardless of community) selected. Suppose among these 12: 5 are women.

Step 2 — Fill Vertical Quotas: Fill SC (4), ST (2), BC (8), EWS (3) by merit within each category. Suppose:

• SC 4 selected: 1 woman

• ST 2 selected: 1 woman

• BC 8 selected: 2 women

• EWS 3 selected: 1 woman

Total women so far: 5 (OC) + 1 (SC) + 1 (ST) + 2 (BC) + 1 (EWS) = 10 women out of 30 = 33.3% ✓

Women's quota is satisfied. No further adjustment needed.

Alternate Scenario — only 7 women are in the list (23.3%, below 33⅓%):

Shortfall = 10 (required) – 7 (found) = 3 women.

Take the next 3 women in merit order — 1 OC woman, 1 SC woman, 1 BC woman — and delete 3 men from the bottom of the respective category lists (1 OC man, 1 SC man, 1 BC man deleted).

Final list: 30 candidates, of which exactly 10 are women.

7.4 Illustration: PBD Block System

Scenario: Department Y has 80 vacancies in a year. PBD register starts fresh.

• Block 1 (Points 1–25): Only 2 of the 25 vacancies in this block are identified as suitable for PBD (one for category (a) Blind/Low Vision, one for category (b) Deaf/Hearing).

  • Point 1 is earmarked for category (a). One blind candidate appointed.

  • Point 26 is earmarked for category (b). One deaf candidate appointed.

  • If no suitable vacancy exists at Point 1, any vacancy from Points 2–25 serves for category (a).

• Since Block 1 yielded only one PBD appointment instead of one per block (Points 1, 26, 51, 76 earmarked for four categories), the carry-over kicks in: one additional PBD vacancy is taken from Block 2.

• If block carry-over is necessary, the department ensures that by the end of 100 points, 4 PBD candidates (4% of 100 = 4) have been appointed.

• After three cycles (300 points), the department checks: are 33⅓% of all PBD appointees women? If not, the shortfall adjustment is made.

7.5 Illustration: Ex-Servicemen Horizontal Reservation

Scenario: 100 posts recruited. 2% ex-servicemen = 2 posts.

• Rule: 1 post must go to a woman ex-serviceman (if available). If no woman ex-serviceman is available, both posts go to male ex-servicemen.

• If no ex-serviceman at all is available, the 2 posts lapse — they are returned to the Open Competition category for that recruitment cycle. No carry-forward to the next year.

• An SC ex-serviceman selected under the ex-servicemen quota is adjusted against the SC point in the vertical reservation roster; a general category ex-serviceman is adjusted against an OC point.

7.6 Illustration: Meritorious Sportspersons

Scenario: 100 posts, 2% sportspersons = 2 posts.

• A BC-B sportsperson selected under sports quota is adjusted against a BC-B point in the vertical roster.

• An OC sportsperson is adjusted against an OC point.

• If no eligible sportsperson is available in any category, the 2 posts lapse and are treated as OC vacancies in that recruitment. No carry-forward.

Part VIII: Notifications and Advertisement Requirements

8.1 Duty to Disclose in Advertisements

The advertisement or notification for any recruitment must clearly specify:

• The total number of vacancies post-wise;

• The category-wise distribution of vacancies (OC, SC, ST, BC-A through E, EWS);

• The roster point from which the last recruitment was concluded;

• The roster point from which the new recruitment commences;

• The adequacy of representation status for women, PBDs, ex-servicemen, and sportspersons.

G.O.Ms.No.77 specifically directs that Administrative Departments, while sending indents to APPSC or any other recruiting agency, must "clearly mention quota-wise, Roster points where the last recruitment was stopped and Roster Points for the new recruitment is to be commenced and the adequacy shall be clearly specified."

8.2 Application Form Requirements

The application form must require candidates claiming horizontal reservation (PBD, ex-servicemen, sportspersons) to indicate their vertical category (SC/ST/BC/EWS/General). This is essential because the selected horizontal candidate must be placed at the correct point in the vertical roster.

8.3 Register Maintenance

Each department must maintain:

• The 100-point vertical reservation roster register (for SC/ST/BC/EWS recruitment);

• A separate 100-point PBD reservation register per post (block-based);

• A separate women's register for SC, ST, and PBD categories (for promotion purposes).

Part IX: Key Case Law Summary

Part X: Common Misconceptions Addressed

Misconception 1: "If an SC candidate wins on open merit, the SC quota is reduced."
Correction: Absolutely not. A vertical reservation candidate who wins a post on open merit does not consume the community quota. The quota remains fully intact. (Indra Sawhney; Rajesh Kumar Daria.)

Misconception 2: "An ex-serviceman selected under the sports quota can claim both quotas."
Correction: No. Quota claims are category-specific. A candidate who applies under one horizontal quota must indicate their vertical category but cannot simultaneously benefit from two horizontal quotas.

Misconception 3: "If no woman is available for a reserved post, the post carries forward to next year."
Correction: No. Under G.O.Ms.No.77, the carry-forward rule does not apply to horizontal reservations (women, ex-servicemen, sportspersons). However, for PBDs, a limited block carry-over within the same 100-point cycle is permitted.

Misconception 4: "OBC/BC employees can get reservation in promotions."
Correction: No. The Supreme Court in Indra Sawhney excluded OBCs from promotion reservations, and no constitutional amendment has altered this. G.O.Ms.No.77 reconfirms: "There is no reservation in promotion for the categories of Backward Classes, Ex-Servicemen, Meritorious Sportspersons and Economically Weaker Sections (EWS)."

Misconception 5: "A person with a temporary disability certificate is entitled to PBD reservation."
Correction: No. G.O.Ms.No.77 specifically provides: "No benefit of reservation shall be given on the basis of temporary certificate of disability." Only a valid, permanent benchmark disability certificate indicating 40% or more disability qualifies.