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Union Public Service Commission v. M. Sathiya Priya and Others

Civil Appeal · 2018 INSC 335Decided 13 Apr 2018
Civil Appeal No. 10854 of 2014
Justice Mohan M. Shantanagoudar · Justice Navin Sinha

Background

A Deputy/Superintendent of Police in Tamil Nadu's State Police Service was considered for promotion to the IPS for the 2008 select list but was graded only "Good" and left out, while some of her juniors were selected. She challenged this before the Central Administrative Tribunal (CAT), arguing her service record deserved an "Outstanding" or "Very Good" grading; the CAT and the Madras High Court agreed and directed her appointment to the IPS with retrospective seniority. The UPSC appealed to the Supreme Court, arguing the Tribunal and High Court had wrongly substituted their own assessment for that of the expert Selection Committee, and had even used the wrong set of years' records for the assessment.

Decision Breakdown

The Supreme Court held that the CAT and High Court had used the wrong period of Annual Confidential Reports (ACRs): they considered records up to 2008 instead of the correct cut-off of 31 March 2007, as required by the applicable Regulations and Guidelines. More importantly, the Court held that courts and tribunals cannot sit as an "appellate authority" over the merit-based classification made by an expert Selection Committee; such decisions can only be interfered with if there is bias, mala fide intent, or arbitrariness, none of which was shown here. Since the Selection Committee's assessment process was fair and followed the prescribed procedure, the Court set aside the CAT and High Court judgments and allowed the UPSC's appeal.

Lesson Learnt

Courts give wide deference to expert selection/promotion committees in government service: an employee cannot get a court to re-grade their own performance record merely by disagreeing with the committee's assessment; they must show actual bias, mala fide intent, or arbitrariness in the process.

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

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