The Court affirms the validity of setting minimum merit standards for promotions under "seniority-cum-fitness" criteria.
In a significant judgment delivered on January 29, 2026, the Chhattisgarh High Court Division Bench, comprising Chief Justice Ramesh Sinha and Justice Parth Prateem Sahu, upheld the authority of the Departmental Promotion Committee (DPC) to establish minimum benchmarks for evaluating the suitability of candidates for promotion based on the "seniority-cum-fitness" criterion. The judgment addressed the ongoing debate regarding the criteria for promotion within the Chhattisgarh Horticulture (Gazetted) Service.
The case involved petitioner Rukam Singh Tomar, who challenged his supersession by a junior colleague, arguing that he met the seniority criterion and had no adverse remarks against him. The DPC, however, had set a requirement for "Good" grading in the Annual Confidential Reports (ACRs) over the preceding five years, absence of 'D' grades, and no adverse remarks, which Tomar failed to meet.
The Court clarified that seniority alone does not guarantee promotion; a candidate must meet minimum merit and fitness requirements, as prescribed by the DPC. This decision aligns with Rule 6(5) of the Chhattisgarh Public Service (Promotion) Rules, 2003, and the Chhattisgarh Horticulture (Gazetted) Service Recruitment Rules, 2013, reinforcing the DPC's role in ensuring that promotions are granted based on both seniority and fitness.
The judgment examined previous rulings, including the Harikrishna Patel case, which argued against benchmarks, and the Prahlad Singh Gunwan case, which supported the DPC's authority to prescribe minimum benchmarks based on ACR grading. The Court favored the latter, emphasizing the importance of assessing candidates' suitability beyond mere seniority.
The Court's decision underscores the necessity of balancing seniority with merit in public service promotions, ensuring that only candidates who meet established standards are promoted. This ruling is expected to guide future promotion evaluations, emphasizing the merit-based assessment of candidates.
Bottom Line:
Promotion criteria based on "seniority-cum-fitness" allows the Departmental Promotion Committee (DPC) to prescribe a minimum benchmark for assessing suitability, including evaluation of Annual Confidential Reports (ACRs) and absence of adverse remarks.
Statutory provision(s): Chhattisgarh Public Service (Promotion) Rules, 2003, Chhattisgarh Horticulture (Gazetted) Service Recruitment Rules, 2013, Articles 16 and 335 of the Constitution of India.
Rukam Singh Tomar v. State of Chhattisgarh, (Chhattisgarh)(DB) : Law Finder Doc id # 2845792
