State of Rajasthan v. Ucchab Lal Chhanwal, (2014) 1 SCC 144
Service Law
Promotion
Necessary parties - Non-impleadment of - Effect - Dispute regarding promotion affecting inter se seniority - Juniors
promoted, not arrayed as parties - Held, once respondents are promoted, juniors who had been promoted earlier would
become juniors in promotional cadre, and they not being arrayed as parties, an adverse order cannot be passed against
them as that would be against the principles of natural justice - Impugned judgment to the extent it directs grant of
promotion to respondents, quashed, (2014) 1 SCC 144-A
Administrative Law
Administrative Action
Administrative Orders/Decisions/Executive Instructions/Orders/Circulars - Retrospective application of circular affecting
promotional policy - Impermissibility - On facts held, Circular dt. 26-7-2006 was not applicable, since controversy
regarding promotion pertained to the year 1996-1997, (2014) 1 SCC 144-B
Service Law
Promotion
Necessary parties - Non-impleadment of - Effect - Dispute regarding promotion affecting inter se seniority - Juniors
promoted, not arrayed as parties - Held, once respondents are promoted, juniors who had been promoted earlier would
become juniors in promotional cadre, and they not being arrayed as parties, an adverse order cannot be passed against
them as that would be against the principles of natural justice - Impugned judgment to the extent it directs grant of
promotion to respondents, quashed, (2014) 1 SCC 144-A
Administrative Law
Administrative Action
Administrative Orders/Decisions/Executive Instructions/Orders/Circulars - Retrospective application of circular affecting
promotional policy - Impermissibility - On facts held, Circular dt. 26-7-2006 was not applicable, since controversy
regarding promotion pertained to the year 1996-1997, (2014) 1 SCC 144-B
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