H.S. Vankani & Ors vs State Of Gujarat & Ors

The Supreme Court addressed the seniority dispute between the 1979-81 batch (non-graduates) and the 1980-81 batch (graduates) of direct recruits in the Gujarat Subordinate Forest Services, governed by the Rangers (Subordinate Forest Service) Recruitment Rules, 1969. The Court held that seniority should be determined based on the final examination ranks as per Rule 14 of the 1969 Rules, irrespective of the date of joining. The Court affirmed the principle that educational qualifications and the completion of training are critical for determining eligibility and seniority in promotions.