Punjab & Haryana High Court, Chandigarh
Citation(1990) 2 SCC 715
CourtSupreme Court of India (Constitution Bench)
Date12 February 1990
Year1990
BenchE.S. Venkataramiah CJI, S. Natarajan, K.N. Singh, M.N. Venkatachaliah, K. Jagannatha Shetty JJ.
Acts/ArticlesArticle 14, Article 16
CategoryConstitutional Law, Service & Employment Law

Key Principle Established

Seniority between direct recruits and promotees must be determined by quota-rota rule. Once the quota is filled, seniority is determined by the date of continuous officiation in the cadre.

Brief Facts

A dispute arose between direct recruit Class II Engineering Officers and promotees regarding inter se seniority. The question was how seniority should be determined when recruitment is from two sources — direct recruitment and promotion.

Ratio Decidendi

The Constitution Bench laid down the quota-rota rule for determining seniority:

  • Where recruitment is from two sources, seniority follows the quota-rota rule — vacancies must be filled in the proportion prescribed for each source
  • Once the quota is filled, seniority is determined by continuous officiation in the cadre
  • If the quota is not adhered to, adjustments must be made to restore the prescribed proportion
  • Ad hoc or temporary service does not count for seniority unless regularized

Impact & Significance

This Constitution Bench decision is the leading authority on seniority disputes between direct recruits and promotees. It is cited in virtually every service law case involving inter se seniority determination.

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Disclaimer

This judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).

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