Dwarka Prasad And Others vs Union Of India And Others

The Supreme Court examined the validity of the 20% promotion quota for Preventive Officers (POs) compared to the 75% quota for Examining Officers (EOs) under the Department of Revenue (Custom Appraisers Recruitment) Rules, 1988, framed under Article 309 of the Constitution. The Court held that the fixation of such a low quota for POs is arbitrary and discriminatory, violating Articles 14 and 16 of the Constitution, as it does not reflect the proportionality principle based on cadre strength. The Court overturned the Central Administrative Tribunal's decision, affirming the need for equitable promotion opportunities among different categories of officers.