Authorities directed to decide objections against provisional gradation lists within a specified time-bound period.

The Petitioner, an Associate Professor at Pt. J.N.M. Medical College, Raipur, approached the High Court seeking a direction to the Respondents to include her name in the Gradation List of Associate Professors and consider her for promotion to the post of Professor

Following the publication of a provisional gradation list, the Petitioner and three others submitted formal objections to the Commissioner of Medical Education on September 26, 2025

The State Respondents filed an affidavit via the Commissioner stating that these objections were under active consideration and a decision would be rendered within three weeks in accordance with applicable rules

An intervenor, ranked first in the preliminary list, sought to participate in the proceedings, arguing that any relief granted to the Petitioner would adversely affect her seniority

1. Whether the respondent authorities are legally obligated to decide pending objections to a provisional gradation list within a reasonable timeframe

2. Whether a third party (intervenor) has locus standi to intervene in a writ petition at the stage where the administrative authority is still considering preliminary objections to a provisional list

The Court applied the principles of administrative law governing the finalization of seniority lists, which require authorities to decide objections through "due process of law" and "strictly in accordance with law while keeping in mind the rules and regulation"

The Court also applied the doctrine of locus standi, holding that an intervention is "premature" when the administrative decision-making process is ongoing and no final order affecting the third party's rights has been passed

The Court noted that the Petitioner’s primary grievance was the administrative delay in deciding her objection to the provisional gradation list

The Court accepted the State’s submission and affidavit, which acknowledged the pending objections and committed to a time-bound resolution

Regarding the intervenor, the Court reasoned that because the department was still in the process of evaluating the objections, the intervenor’s rights had not yet been finalized or infringed upon

The Court held that it is the duty of the respondent authorities to decide such objections independently by following the prescribed rules and regulations

Consequently, the Court found that the intervenor had no standing to interfere with the administrative process at this preliminary stage

The Court held that the intervenor had no locus at this stage but granted her the liberty to file appropriate proceedings should she feel aggrieved by the final decision taken by the authorities