VidhiSangh

Supreme Court of India · 23/04/2025

RAJU NARYANA SWAMY versus STATE OF KERALA & ORS.

[2025] 4 S.C.R. 1723 · 2025 INSC 563

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Summary

The Supreme Court dismissed an IAS officer's challenge to the rejection of his review application against non-empanelment for promotion to the Chief Secretary grade. Applying the principles in Badrinath, the Court held that the Review Committee could consider the entire service record; adverse entries prior to the 2016 promotion were weak material but a continuing post-promotion trend of indiscipline, including a year of unauthorised absence in 2019-20, justified the decision, which was neither mala fide nor Wednesbury unreasonable.

Issues

  1. Whether the Review Committee travelled beyond the reasons of the Screening Committee by relying on additional or extraneous material, including adverse ACR entries prior to the appellant's 2016 promotion, a fact-finding report and observations of the CAT.
  2. Whether adverse ACR entries relating to a period before an earlier promotion can be considered in assessing suitability for a further promotion.
  3. Whether the failure to fix a benchmark score rendered the assessment arbitrary or discriminatory.
  4. Whether the decision denying promotion warranted interference as mala fide or unreasonable.

Provisions considered

Held

Result

Appeal dismissed; the High Court's order, which had left the appellant at liberty to approach the authorities for preparation of his ACRs and reconsideration for promotion after 90% of ACRs are available, was not interfered with.

Judgment PDF: Supreme Court of India, [2025] 4 S.C.R. 1723.