भारत संघ बनाम के.वी. जानकीरमन
| Citation | (1991) 4 SCC 109 |
| Court | Supreme Court of India |
| Date | 21 August 1991 |
| Year | 1991 |
| Bench | K.N. Saikia, S.R. Pandian JJ. |
| Acts/Articles | Article 14, Article 16, Article 311 |
| Category | Service & Employment Law |
Key Principle Established
Sealed cover procedure — where departmental proceedings are pending, employee can be considered for promotion but result kept in sealed cover pending outcome of proceedings.
The question arose whether government employees facing departmental or criminal proceedings should be considered for promotion by the DPC, or their cases deferred entirely.
The Supreme Court introduced the sealed cover procedure:
The sealed cover procedure is standard practice in all government services across India. It balances the right of the employee to be considered for promotion with the need to await outcome of pending proceedings. This judgment is relied upon in every promotion dispute involving pending disciplinary matters.
2014 SCC OnLine P&H 22487
Government policy on regularization of contractual employees under HKRNL must be implemented uniformly. Selective application violates Article 14.
Read Analysis(2008) 9 SCC 284
University recruitment must follow UGC norms and guidelines. Appointments made in violation of minimum qualification requirements are void ab initio.
Read Analysis(1993) 2 SCC 411
Recruitment bodies must follow fair and transparent selection processes. Any irregularity in the recruitment process vitiates the entire selection.
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.