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Prem Narayan Singh & Ors. v. Hon'ble High Court of Madhya Pradesh

Writ Petition (Civil) · 2021 INSC 399Decided 12 Aug 2021
Writ Petition (Civil) No. 1069 of 2019
Justice L. Nageswara Rao · Justice Aniruddha Bose

Background

The petitioners were District Judges in Madhya Pradesh who had been promoted through a merit-based Limited Competitive Examination (LCE) meant to reward high-performing junior judicial officers. The High Court's Administrative Committee later decided, and the Full Court approved, that for seniority purposes among those promoted via the LCE, seniority would be based on their rank in the lower cadre rather than their merit in the LCE itself, and a revised seniority list was issued accordingly to the petitioners' disadvantage. The petitioners challenged this decision and the revised gradation list directly before the Supreme Court.

Decision Breakdown

The Supreme Court held that the High Court's Administrative Committee decision was contrary to an earlier binding Supreme Court ruling (Dinesh Kumar Gupta) which held that seniority among candidates promoted through a merit-based LCE must be based on their LCE merit, not on their seniority in the lower cadre: otherwise the entire incentive of the merit-based examination would be defeated. The Court rejected the argument that this earlier ruling was wrongly decided, and also noted that the 2017 service rules themselves protected the seniority of officers who were already holding their posts before the new rules came into force. It set aside the Administrative Committee's resolution and directed that the gradation list of District Judges be revised in line with the merit-based principle.

Lesson Learnt

When a government or judicial institution creates a competitive, merit-based promotion scheme as an incentive, it cannot later undermine that incentive by changing the seniority rules to favor plain cadre seniority over the merit that was actually tested and rewarded.

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

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