Chhattisgarh High Court

Authorities must consider promotion claims in strict adherence to seniority when issuing fresh promotion orders.

CHANDAN SINGH USANDI vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: March 24, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners, working as a Ward Boy and Class-IV Labour respectively, challenged a promotion order dated 13.11.2020 issued by the Chief Medical and Health Officer (Respondent No. 5), whereby their juniors were promoted to the posts of Assistant Grade-III and Dresser Grade-II.

Source reference: para 1

Although the State Government subsequently cancelled these promotion orders on 30.03.2021, a Coordinate Bench of the High Court in WPS No. 2577/2021 (and connected matters) quashed the cancellation on 05.02.2026.

Source reference: para 1-2

The Coordinate Bench directed the respondent authorities to pass fresh orders regarding those promotions in accordance with the law after providing a hearing to the affected parties.

Source reference: para 1, 4

The petitioners sought a direction to be considered for promotion over the private respondents in this fresh exercise.

Source reference: para 1
02

Issues

Whether the petitioners are entitled to be considered for promotion to Assistant Grade-III and Dresser Grade-II during the fresh adjudication of the promotion orders directed by the Coordinate Bench?

Source reference: para 1, 4
03

Law Applied

The court applied the principles of administrative fairness and adherence to seniority in public employment.

Source reference: no citation

It primarily relied on the judicial directions issued in the previous litigation (WPS No. 2577/2021), which mandated that the respondent authorities must pass fresh orders regarding disputed promotions strictly in accordance with the law and after affording an opportunity of hearing to the concerned parties.

Source reference: para 1, 4
04

Reasoning

The court observed that the original promotion orders were currently under re-evaluation due to the judgment dated 05.02.2026 in WPS No. 2577/2021, which quashed the State's cancellation of said promotions.

Source reference: para 4

The court reasoned that since the authorities were already tasked with passing fresh orders, the petitioners should be permitted to present their claims of seniority and entitlement to the respondent authorities.

Source reference: para 4

To ensure a fair process, the court linked the resolution of the petitioners' grievances to the existing seniority list, determining that the authorities must evaluate the petitioners' claims for promotion to higher posts (Assistant Grade-III and Dresser) while strictly honoring that list.

Source reference: para 5
05

Holding

The High Court disposed of the writ petitions by granting liberty to the petitioners to submit a detailed representation to Respondent No. 5 (CMHO, Jagdalpur).

The court directed Respondent No. 5 to consider the names of the petitioners for promotion to Assistant Grade-III and Dresser, ensuring that any decision taken honors the relevant seniority list.

Source reference: para 4-5

No order as to costs was made.

Source reference: para 7
Chhattisgarh High Court

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CHANDAN SINGH USANDIvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · March 24, 2026

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