SARAT CHANDRA MISHRA vs STATE OF ORISSA .

The Supreme Court upheld the Orissa Administrative Tribunal's decision which quashed the circular dated 21.02.1989 and the subsequent Gradation List dated 22.08.1990, ruling them illegal. The Court established that seniority among Lower Division Assistants should be based on the ranks obtained in the PSC examination, not on fortuitous circumstances such as training timelines. The Court affirmed that future promotions must adhere to the 1984 Gradation List, thereby reinforcing the principle of seniority based on examination results as per the OMS Rules, 1951.