Summary
A rural bank could prescribe minimum interview and performance-appraisal marks to assess merit for promotion governed by seniority-cum-merit, even though the rules specified only a written-test threshold. Once candidates crossed the valid benchmarks, promotion had to follow seniority rather than comparative total marks. The Supreme Court rejected wholesale cancellation of the selection exercise and required a fresh select list using the written-test and additional benchmarks already applied.
Issues
- Whether additional minimum merit benchmarks conflicted with seniority-cum-merit.
- Whether the entire promotion exercise required cancellation.
- How the fresh select list was to be prepared.
Held
- The committee’s requirement of at least twelve out of twenty marks each in interview and performance appraisal was permissible. Assessing minimum necessary merit through those benchmarks did not itself substitute merit-cum-seniority for the governing standard. (¶¶ 9, 11–12)
- After the qualifying written-test marks and the two additional thresholds were met, candidates had to be promoted in seniority order irrespective of higher marks obtained by another qualifying candidate. (¶ 12–13)
- Without a finding that irregularity vitiated the entire selection exercise, the Division Bench was unjustified in requiring that exercise to be conducted anew. The appropriate course was preparation of a fresh select list applying the valid thresholds and seniority. (¶¶ 10, 13)
Result
Appeals allowed to the stated extent without costs. Both High Court judgments set aside. Authority directed to prepare a fresh promotion list of candidates meeting the written-test threshold and twelve marks each in interview and appraisal, ranked by seniority.