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j) That the juniors of the Applicant have been promoted even in subsequent panels and no provision for the Applicant has been made, and denying him promotion in backdate will unlawfully jeopardise his seniority within the department.
k) That the Respondents have allowed similarly placed MCM to be promoted and retained.
l) That denial of promotion and retaining in Mumbai would be illegal and arbitrary on the part of the Respondents.