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Pankaj Prakash vs. United India Insurance Co. Ltd.

Civil Appeal · 2022 INSC 324Decided 22 Mar 2022
Civil Appeal No. 2213 of 2022

Background

The appellant, a Deputy Manager at United India Insurance, was repeatedly denied promotion to Manager. An earlier round of litigation over his non-promotion for 2014 reached the Supreme Court, which in 2019 ruled that the company had wrongly failed to communicate his Annual Performance Appraisal Reports and directed a fresh review; that review process was still pending before the Delhi High Court. Separately, the appellant filed a fresh case before the Allahabad High Court (Lucknow Bench) about his non-promotion for the subsequent years, 2015 and 2016, and that Court dismissed his petition, mistakenly recording that he had never challenged the earlier adverse orders (when in fact that challenge had already succeeded before the Supreme Court).

Decision Breakdown

The Supreme Court found the Lucknow Bench's judgment factually incorrect, since it overlooked that the appellant's earlier challenge (for 2014) had already been decided in his favour by the Supreme Court in 2019 and was still being reconsidered by the Delhi High Court. Because the outcome of that pending 2014 matter could affect the appellant's promotion claims for 2015 and 2016 as well (since performance appraisal records are relevant to both), the Court set aside the Lucknow High Court's judgment and ordered that the Lucknow case be transferred to the Delhi High Court, to be heard together with the pending 2014 case, so both years could be decided consistently by the same bench.

Lesson Learnt

When related service disputes spanning different years are being litigated in different courts, and the outcome of one materially affects the other, courts will consolidate them before a single forum rather than let inconsistent findings develop, and a party's rights should be assessed on the true procedural history, not an inaccurate summary of it.

Official source (sci.gov.in)View Judgment (PDF)

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