DWARKA PRASAD vs UOI

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 of India. The Court held that the fixation of such a low quota for POs was arbitrary and discriminatory, violating Articles 14 and 16 of the Constitution, as it did not reflect the proportionality principle based on cadre strength. Consequently, the Court set aside the tribunal's order and ruled in favor of the appellants, affirming their right to a fair promotion quota.