सीधी भर्ती वर्ग-II इंजीनियरिंग अधिकारी बनाम महाराष्ट्र राज्य
| Citation | (1990) 2 SCC 715 |
| Court | Supreme Court of India (Constitution Bench) |
| Date | 12 April 1990 |
| Year | 1990 |
| Bench | M.N. Venkatachaliah, S. Ratnavel Pandian, A.M. Ahmadi, K. Jayachandra Reddy, N.D. Ojha JJ. |
| Acts/Articles | Article 14, Article 16 |
| Category | Constitutional Law, Service & Employment Law |
Key Principle Established
Seniority between direct recruits and promotees must be determined by quota-rota rule. Length of continuous officiation determines seniority within each category.
A dispute arose between directly recruited Class II Engineering Officers and those promoted from Class III regarding inter se seniority. The question was whether promotees who officiated for longer periods should be senior to direct recruits appointed later.
The Constitution Bench established the comprehensive framework for seniority determination:
This is the foundational judgment on inter se seniority between direct recruits and promotees. Every seniority dispute in government service — including the Haryana cases involving Municipal Corporation engineers — relies on the principles laid down here. The quota-rota formula remains the standard method for determining seniority across India.
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Read AnalysisThis 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).
22+ years of practice before Punjab & Haryana High Court and Supreme Court of India.