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O.P. Singla & Anr. Etc vs Union Of India & Ors on 14 August, 1984

Now proceeding on the assumption that Rule 25 (I) (ii) is valid and therefore seniority inter-se between recruits from three different sources has to be computed according to the quota by rotating substantive vacancies in the grade reserved for each source, if in actual implementation it creates disparities between persons who are similarly circumstanced and thereby deny equal treatment, the rule would be violative of Art. 16. The outcome is not on account of an invidious implementation of the rule but non- implementation of a part of rule for years. The end product as will be demonstrably established is unjust and unfair and yet this unjust and unfair action is being sup- ported by the Union of India which was responsible for utter inaction in implementing the rule in its letter and spirit and for unreasonably long intervals. As pointed out earlier, direct recruitment has not been made for years. Limited competitive examination has also not been held for years. Promotions from the select list have been presumably in excess of the quota but they were appointed to substantive vacancies in the service and have been holding the posts as in the case of petitioners for over 6 to 8 years. The promotions were not styled as temporary, adhoc or stop-gap- Blanks related to allocated vacancies kept open for future direct recruits and candidates qualifying at limited competitive examination in the seniority list indicate 17 that if the next direct recruitment is made, say in 1990 and the limited competitive examination is held in 1988, the recruits from the aforementioned two sources will have to be placed at Sr. No. 170 in the case of direct recruits and little down below in case of a candidate qualifying at the limited competitive examination. The direct recruit already placed at Sr. No Fin 170 in 1990 would score a march over departmental promotees of 1978 and persons in service after qualifying at the limited competitive examination in 1988. The emerging situation would be in pari materia with what was found by this Court in Janardhana's case and O.P. Singla's case and the reasons therein mentioned will mutatis mutandis apply for quashing the seniority list for the self same reason.
Supreme Court of India Cites 17 - Cited by 150 - Y V Chandrachud - Full Document

S. G. Jaisinghani vs Union Of India And Ors.(With Connected ... on 22 February, 1967

Now turning to the impugned seniority lists, what the Union of India appears to have done is that it has applied the quota and rotated the vacancies but where candidates from a particular source were not available, the vacancies were deemed to be kept open (some kind of carry forward) to be filled in by later recruitment from the same source years after the vacancy occurred, but in the meantime the vacancy was filled in presumable by excess recruitment from the other sources. That is clearly either non-implementation of the quota rule or mal-functioning of the quota rule and yet the rota rule is adhered to which is both impermissible under the Rules as well as unjust, unfair and inequitous being violative of Arts. 14 and 16. 1) It was however contended on behalf of the respondents that the quota prescribed by Rule 13(1) being mandatory in character, any appointment in excess of the quota in any year would render the excess appointees as irregularly appointed and they would not become members of the service and hang outside the service, and can be demoted. It was said that once recruits are available from the source for which quota was prescribed, the promotees in excess Or their quota can and must be replaced by later entrants. It was submitted that such excess promotees have to be demoted but to solve them from this harsh situation, the courts have evolved a rule that they may be pushed down and regularised in subsequent years. This indulgence, it was said, cannot be claimed as a matter of right and therefore such excess promotees cannot claim seniority over recruits from other sources who may have come at a later date. Reliance was placed in two decisions of this Court in S.G. Jaisinghani v. Union of India & Ors. (1) and Bishan Sarup Gupta etc. v Union of India & Ors. (2) These two decisions are of little help in; view of the later decisions directly on the point and discussed hereinabove, (1) [1967] 2 S.C.R.. 703, (2) [1975] 1 S.C.R. 104, 456 The language of Rule 13(1) appears to be mandatory in character. Where recruitment to a service or a cadre is from more than one source, the controlling authority can prescribe quota for each source. It is equally correct that where the quota is prescribed, a rule of seniority by rotating the vacancies can be a valid rule for seniority. But as pointed out earlier if the rule of seniority is inextricably intertwined with the quota rule and there is enormous deviation from the quota rule, it would be unjust, inequiutous and unfair to give effect to the rota rule. In fact as held in O.P. Singla's case, giving effect to the rota rule after noticing the enormous departure from the quota rule would be violative of Art. 14. There fore assuming that quota rule was mandatory in character as pointed out earlier, its departure must permit rejection of rota rule as a valid principle of seniority;
Supreme Court of India Cites 9 - Cited by 365 - V Ramaswami - Full Document

A. Janardhana vs Union Of India And Others on 26 April, 1983

inferred from various relevant circumstances then prevailing that the appoints not in consonance with the prescribed procedure for direct recruitment must have been made in relaxation of the rules. When the question again came up in Janardhana's case the Court held that if direct recruitment was made in relaxation of the relevant rules, the same reasons will mutatis mutandis apply to hold that promotions in excess of quota were given by relaxing the rules. It is therefore reasonable to believe in this case that though the quota was mandatory it was not adhered to by exercising the power of relaxation both qua persons and posts.
Supreme Court of India Cites 5 - Cited by 238 - D A Desai - Full Document

N.K. Chauhan & Ors vs State Of Gujarat & Ors on 1 November, 1976

Once there is power to relax the mandatory quota rule, the appointments made in excess of the quota from any given source would not be illegal or invalid but would be valid and legal as held by this Court in N.K. Chandan and Ors. v. State of Gujarat(2). Therefore the promotion of the promotees was regular and legal both on account of the fact it was made to meet the exigencies of service in relaxation of the mandatory quota rule and to substantive vacancies in service.
Supreme Court of India Cites 12 - Cited by 142 - V R Iyer - Full Document

State Of U. P vs Manbodhan Lal Srivastava on 20 September, 1957

Coming home in h State of U.P. v. Manbodon Lal Srivastava(1) a Constitution Bench of this Court specifically held that where consultation with the Public Service Commission is provided as required by Art. 320(3)(c) of the Constitution such provision is not mandatory and they do not confer any rights on public servants so that the absence of consultation or irregularity in consultation does not afford him a cause of action in a court of law. There are number of subsequent decisions to which our attention was called reiterating the same principle. Therefore assuming there was failure to consult the Union Public Service Commission before exercising the power to relax the mandatory quota rule and further assuming that the posts in Integrated Grade II and Ill were within the purview of the Union Public Service Commission and accepting for the time being that the Commission was not consulted before the power. to relax the rule was exercised yet the action taken would not be vitiated nor would it furnish any help to Union of India which itself cannot take any advantage of its failure to consult the Commission. Therefore it can be safely stated that the enormous departure from the quota rule year to year permits an inference that the departure was in exercise of the power of relaxing the quota rule conferred on the controlling authority.
Supreme Court of India Cites 13 - Cited by 553 - B P Sinha - Full Document
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