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Issues: Whether a writ of mandamus could be issued to require the State to collect quantifiable data and undertake the exercise necessary for deciding reservation in promotion under Articles 16(4-A) and 16(4-B) of the Constitution of India.
Analysis: Articles 16(4-A) and 16(4-B) are enabling provisions. The State is not bound to make reservation in promotion, and the decision to do so depends on satisfaction of the constitutional conditions identified in M. Nagaraj, including backwardness, inadequacy of representation and compliance with Article 335. The demand for a mandamus to collect data would amount to directing the State to take steps toward exercising a discretion that the Constitution leaves to it, which is not the same as enforcing a pre-existing legal duty. The Court also held that issuing such a direction would intrude into the domain of policy and legislative choice.
Conclusion: No mandamus could be issued to compel the State to collect data or proceed toward framing reservation in promotion.
Final Conclusion: The writ petitions were rejected because the relief sought lay beyond the proper scope of mandamus and the enabling constitutional scheme left the decision to the State's discretion.
Ratio Decidendi: A writ of mandamus cannot be used to compel the State to undertake the preliminary exercise required for a discretionary, enabling constitutional power where no enforceable legal duty to act exists.