CAT - ['Chandigarh']

Candidate's successful performance in departmental examination necessitates formal promotion process despite prior eligibility disputes regarding probation.

Anil Kumar vs DEPTT OF POSTS

CAT - ['Chandigarh']JUDGMENT: April 23, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicants, initially engaged as Gramin Dak Sevaks (GDS), were appointed as Multi-Tasking Staff (MTS) in 2021

Source reference: p.2

After completing a two-year probation in March 2024, they were promoted to Lower Division Clerks (LDC) in late 2025

Source reference: p.3

the respondents issued an Office Memorandum (OM) dated 04.02.2026, stipulating that candidates must complete both probation and the required qualifying service by the crucial date of 01.01.2026

Source reference: p.3

Under interim directions from the Tribunal dated 06.02.2026, the applicants appeared for the examination provisionally

Source reference: p.3-4

A departmental scrutiny committee subsequently found both applicants eligible

Source reference: p.4
02

Issues

1. Whether the applicants are eligible to appear for the departmental examination for promotion to Junior Accountant despite the restrictive conditions in the OM dated 04.02.2026.

Source reference: p.2/para. 1

2. Whether the respondents are obligated to proceed with the promotion process after the applicants were found qualified by the scrutiny committee and the examination results.

Source reference: p.4/para. 6
03

Law Applied

CPAO (Junior Accountants, Stenographers, LDC) Recruitment Rules, 2010 (RR 2010), which govern the statutory requirements for promotion to the cadre of Junior Accountant

Source reference: p.2

Ministry of Communication’s OM dated 13.12.2023, which clarified that probation must be completed in the entry grade of service and not necessarily in every subsequent grade

Source reference: p.3

Tribunal utilized its discretionary power to grant interim relief, allowing provisional appearance in examinations to prevent irreparable injury to candidates' career prospects

Source reference: p.3-4
04

Reasoning

The Tribunal analyzed the eligibility of the applicants based on their service record and the findings of the respondents' own Scrutiny Committee.

Source reference: p.4

a committee constituted by the department during the pendency of the litigation reviewed the matter and explicitly declared the applicants eligible to appear for the promotion

Source reference: p.4

The results of the departmental examination, produced in a sealed envelope, confirmed that both applicants had successfully qualified for the post of Junior Accountant

Source reference: p.4

Since the internal departmental committee had already resolved the eligibility dispute in favor of the applicants and they had passed the examination, the Tribunal found there was no further legal impediment to their promotion

Source reference: p.4
05

Holding

The Tribunal held that since the applicants were declared qualified in both the departmental examination and by the internal scrutiny committee, the respondents are legally obligated to finalize their promotion

The Tribunal disposed of the OA by directing the respondents to expedite and complete the promotion process to the post of Junior Accountant

Source reference: p.4
CAT - ['Chandigarh']

Original Court PDF

Anil KumarvsDEPTT OF POSTS

CAT - ['Chandigarh'] · April 23, 2026

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