S. RAJENDIRAN vs U.O.I. .

The Supreme Court held that the promotion of the appellant as Deputy Superintendent of Jails was valid despite the subsequent eligibility of the Scheduled Caste respondent, as he had not completed his probation or passed required tests at the time of the vacancy. The Court emphasized that the rules for promotion under the Recruitment Rules, 1981, necessitate eligibility criteria that must be met prior to promotion. The appeal was dismissed, affirming the Tribunal's decision to not regularize the appellant's appointment due to the procedural adherence to reservation policies under the Government of India guidelines.