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Use small Rossby number $U/(f_{0}l)\ll 1$, slow evolution on the advective time scale, small interface displacements relative to each layer depth, shallow hydrostatic layers, stable reduced gravity $g^{\prime }>0$, and inviscid unforced flow. On a beta plane, take $\beta l/f_0$ of the same small order as the Rossby number. The internal Burger number is retained at order unity so stratification and relative-vorticity effects can both enter the leading potential-vorticity anomaly.

The rigid-lid pressure in two-layer flow comes from neglecting the free-surface volume displacement in the rigid-lid approximation; it does not permit setting the common horizontal pressure gradient to zero. The small surface displacement multiplied by $g$ retains a finite lid-pressure multiplier. Write $h_1=H_1+\chi$, $h_2=H_2-\chi$, and let $\Pi$ denote this common pressure potential. Leading geostrophic balance giveswith ${\mathbf{u}}_i=(-{\psi }_{iy},{\psi }_{ix})$ at leading order. Literally setting $h_1+h_2$ to a spatial constant in the momentum gradients before taking the rigid-lid limit would suppress the upper-layer pressure field and fail to produce general two-layer QG dynamics.

Taking curl of each shallow-water momentum equation and using layer continuity gives material conservation of $(f+{\zeta }_i)/h_i$. Expanding it to first order and advecting the anomaly by the leading geostrophic velocity yieldsThe two-layer quasi-geostrophic potential vorticity equations areHere the common background $f_0/H_i$ has been removed and the anomaly multiplied by $H_i$. The advection term is retained at the same slow order as the time derivative even though the leading velocity/pressure balance was linear geostrophy. On an $f$ plane simply set $\beta =0$.

To recover the printed dispersion relation, interpret the surface maintained flat as an imposed flat upper boundary for the perturbation, so its normal velocity is zero. This is the rigid-lid approximation. Work with perturbation velocity potentials ${\varphi }_{-}=A{e}^{ky}{e}^{ikx+\sigma t}$ below the interface and ${\varphi }_{+}=B\cosh [k(y-h)]e^{ikx+\sigma t}$ in the upper layer. They solve the Laplace equation, decay as $y\to -\infty$, and obey ${\partial }_y{\varphi }_{+}(h)=0$.

The linear kinematic boundary conditions at the interface give $(\sigma +ikU){\eta }_0=kA$ and $\sigma {\eta }_0=-kB\sinh (kh)$. Equality of pressures, using the linear Bernoulli equation, gives $(\sigma +ikU)A=\sigma B\cosh (kh)$. The equal fluid densities cancel the interface gravitational restoring term. Eliminating $A,B,{\eta }_0$ yieldsWith $q=\tanh (kh)$, the roots areFor every $k>0$ one root has positive real part. Thus the vortex sheet has a Kelvin-Helmholtz instability at every wavelength in this model. If $kh\gg 1$, $q\to 1$ and the growing rate is $Uk/2$. If $kh\ll 1$, $q\sim kh$ and it is $Uk\sqrt{kh}$.

There is a physical qualification to the wording. A dynamically deformable free surface at finite gravity is not exactly a flat lid. Its linear conditions combine to ${\sigma }^2{\varphi }_{+}(h)+g{\partial }_y{\varphi }_{+}(h)=0$. Writing the upper potential as $B\cosh (ky)+C\sinh (ky)$ and using the same interface conditions instead givesThe stated quadratic follows in the strong-gravity flat-surface limit, or with the flat condition imposed exactly. It is not the exact dispersion relation of a freely moving upper surface at arbitrary finite $g$. This makes explicit the boundary interpretation needed for the requested formula.

For a zonal basic geostrophic flow $U(y)$, take ${\psi }_0^{\prime }(y)=-U(y)$ and write $\psi ={\psi }_0+\varphi$. The flat-bottom shallow-water quasi-geostrophic potential vorticity gradient of the basic state isLinearizing its material conservation gives the Rossby-wave equation for a sheared zonal current,For a general nonuniform jet, a global two-dimensional plane wave is not an exact normal mode: the coefficients depend on $y$. The exact zonal normal mode problem, $\varphi =\hat{\varphi }(y)e^{i(kx-\omega t)}$, iswith appropriate transverse boundary or radiation conditions. If the jet varies slowly compared with a wavelength, a local plane wave freezes these coefficients at $y_0$. Its local dispersion relation isIn the nondivergent Barotropic Rossby wave model under a rigid-lid approximation, this becomes $\omega =kU-k(\beta -U^{\prime \prime })/(k^2+l^2)$. It is exact for uniform $U$ and otherwise a local relation. Retaining the free-surface term also requires retaining the basic surface slope in $Q_0^{\prime }$; simply adding $R_D^{-2}$ to the denominator while dropping $R_D^{-2}U$ from the numerator would describe a different prescribed-background model.

The rigid-lid approximation removes external surface displacement from volume conservation while retaining its pressure as a constraint multiplier. It does not mean zero horizontal pressure gradient. In two-layer geostrophic flow, $f_0{\psi }_1=\Pi$ and $f_0{\psi }_2=\Pi -g\prime \chi$, so the upper-layer depth anomaly is $\chi =f_0({\psi }_1-{\psi }_2)/g\prime$. This pressure difference supplies internal potential-vorticity coupling.