J. N. GOEL & ORS.G.L. GUPTA Y ORS. vs UNION OF INDIA & ORS.

The Supreme Court addressed the promotion eligibility of Assistant Engineers to Executive Engineers under the Central Engineering Service Group 'A' Recruitment Rules, 1954. It held that only graduate Assistant Engineers are eligible for promotion as per Rule 21(3), which mandates a degree in Engineering for competitive examination eligibility. The Court affirmed the Tribunal's decision that administrative instructions cannot override statutory provisions, thus invalidating promotions based on such instructions, and upheld the need for adherence to the 1954 Rules.