UNION OF INDIA vs DHARAM PAL ETC. .

The Supreme Court addressed the issue of promotion procedures under the Indian Railway Establishment Manual (IREM), specifically Rule 174 and Rule 219, which govern the appointment of Material Checking Clerks (MCC). The Court held that the ad hoc promotions granted to the respondents without following the mandatory selection procedure were invalid, as they did not meet the criteria established in IREM. Consequently, the Court upheld the High Court's decision to regularize the services of the respondents based on their ad hoc service, emphasizing that such regularization should not set a precedent for future cases.