UNION OF INDIA AND ANR. vs MAJ. GEN. DAYANAND KHURANA

The Supreme Court held that the promotion policy under the 'Two Stream Concept' as outlined in the Military Secretary's note dated 22nd September 1986, which adopted Option 'B', was correctly implemented. The Court clarified that officers in the 'Command and Staff' Stream are to be treated as senior to those in the 'Staff Only' Stream, thereby upholding the hierarchy established by the Army's promotion policy. The High Court's order to treat the respondent senior to others in the 'Command and Staff' Stream was set aside, affirming the validity of the promotion criteria established by the Military Secretary.