COAL INDIA LTD. vs SAROJ KUMAR MISHRA

The Supreme Court addressed the promotion rights of employees of Mahanadi Coalfields Ltd. under the Seniority-Cum-Merit rule, emphasizing that pending vigilance cases should not automatically bar promotion unless substantiated by the relevant office memorandums. The Court upheld the Orissa High Court's decision to grant notional promotions to the respondents, stating that the sealed cover procedure was improperly applied in their case. The judgment reinforced the principle that promotions cannot be denied without due process and clear justification under the applicable rules.