Board Of Directors, Represented ... vs Hrusikesh Senapati

The Supreme Court upheld the introduction of the E-O grade in the executive cadre as a valid promotional avenue for S-3 supervisory personnel, finding that the 1984 Recruitment and Promotion Rules do not apply to non-executive employees. The Court noted that a binding settlement under Section 18(3) of the Industrial Disputes Act, 1947, allowed for internal selection to E-O level, thus dismissing the respondents' claims of legitimate expectation for promotion to E-1 level. The Court affirmed the legality of the impugned circular No. 64 dated 29.6.1995, ruling that it did not prejudice the rights of the petitioners.