REGISTRAR OF HIGH COURT OF MADHYA PRADESH AND ANOTHER vs B. A. NIGAM AND OTHERS

The Supreme Court held that under the Madhya Pradesh Civil Courts Act, 1958, experience as a Civil Judge Class I is a necessary qualification for promotion to the post of Additional District and Sessions Judge, not seniority. The Court found that the High Court's resolution of May 1968, which classified Civil Judges for promotion, did not create a new class but established a standard for fitness. The appeal was allowed, affirming that the respondent had no claim to the Class I post before 1968, and seniority in Class II service was irrelevant.