Prafulla Kumar Das And Ors vs State Of Orissa And Ors

The Supreme Court upheld the validity of Section 2 of the Orissa Administrative Service, Class - II (Appointment of Officers Validation) Amendment Act, 1992, affirming that the principle of 'year of allotment' is applicable for determining seniority among officers. The Court clarified that the year of allotment is based on the original proposal for filling vacancies, not the actual appointment date. The judgment confirmed the decision of the Orissa Administrative Tribunal, thereby rejecting the petitioners' claims for retrospective application of the Act and their seniority over direct recruits.