R. PRABHA DEVI & ORS. vs GOVERNMENT OF INDIA, THROUGH SECRETARY,MINISTRY OF PERSONNE

The Supreme Court examined the validity of Rule 12(2) of the Central Secretariat Service Rules, which mandates 8 years of approved service for promotees to be eligible for promotion to Grade I, while allowing direct recruits to be considered without such service. The Court held that this rule is arbitrary and violates Articles 14 and 16 of the Constitution, as it unjustly disadvantages direct recruits by excluding them from promotion consideration based solely on seniority. The Court overturned the Central Administrative Tribunal's decision, ruling that eligibility criteria must be relevant to suitability for promotion.