CHANDER BHAN vs HOTILAL GUPTA AND OTHERS

The Supreme Court upheld the High Court's decision that promotions within the Court of Small Causes must be made by the Judge of the Small Causes Court, as per Rule VI(1) of the High Court Rules, and that the rule of rotation does not apply to such appointments. The Court clarified that the specific mention of the Judge in the rules indicates that the powers of promotion are conferred solely on that officer. The Court found that applying the principle of rotation was unreasonable in the context of the Small Causes Court, where only one Upper Division Clerk exists, distinguishing it from the District & Sessions Court where multiple posts are available.