भारत संघ बनाम के.वी. जानकीरामन
| Citation | (1991) 4 SCC 109 |
| Court | Supreme Court of India |
| Date | 28 August 1991 |
| Year | 1991 |
| Bench | K.N. Saikia, R.M. Sahai JJ. |
| Acts/Articles | Article 14, Article 16, CCS (CCA) Rules |
| Category | Service & Employment Law |
Key Principle Established
A government employee under suspension or facing disciplinary/criminal proceedings cannot claim promotion as of right but is entitled to be considered. Sealed cover procedure established.
The question arose whether government employees who are under suspension or against whom disciplinary or criminal proceedings are pending can be promoted.
The Supreme Court established the sealed cover procedure:
The sealed cover procedure is now universally followed across all government services. It balances the employee’s right to be considered for promotion with the need to ensure that tainted officers are not promoted before their innocence is established.
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.