Challenges to settled seniority raised after decades are barred by laches.

The petitioner joined the CRPF as a Constable/GD (Mahila) in 1994 and was a member of the CRPF water polo team that won a gold medal at the 53rd National Aquatic Championship in 1998.

She sought out-of-turn promotion and consequential seniority as Head Constable under the CRPF policy dated 14 July 1998 and the Office Memorandum dated 26 July 2012.

Although she made repeated representations, she did not challenge the denial of promotion in court for more than two decades.

In response to a legal notice, the CRPF rejected her claim in a communication dated 15 September 2025, stating that the 1998 policy had been discontinued and the 2012 policy did not apply to her.

The petitioner then sought to quash that communication and obtain promotion and seniority from 9 September 1998.

1. Whether the petitioner’s claim for out-of-turn promotion and consequential seniority, raised more than two decades after the alleged denial, was liable to be rejected for delay and laches.

2. Whether the petitioner qualified for out-of-turn promotion under the 26 July 2012 O.M. by establishing that she played at least 50% of the matches in the team event.

3. Whether denial of promotion to the petitioner, despite the alleged promotion of other team members, violated Articles 14, 15 and 16 of the Constitution.

The 26 July 2012 O.M. provides that, in a team event, a sportsperson qualifies for out-of-turn promotion only if they played at least 50% of the matches; a reserve player is not eligible.

Mere membership of a team or receipt of a team medal does not establish eligibility under that criterion; the claimant bears the initial burden of proving active participation.

Under K.R. Mudgal v. R.P. Singh, (1986) 4 SCC 531, challenges to settled seniority must be brought within a reasonable time, as stale claims may unsettle accrued rights and create administrative uncertainty.

The Court distinguished Pradeep Singh v. Union of India, W.P.(C) 7043/2012 (20 April 2015), where the respondents had approved the promotions and delayed processing the claims, unlike the present case.

The Court held that the petitioner knew of the denial of promotion but did not challenge it within a reasonable time; repeated representations over more than two decades did not cure the delay, and her claim also sought to reopen long-settled seniority.

On eligibility, the O.M. required proof that she played at least 50% of the matches. Her representations established team membership and participation in practice sessions as a goalkeeper, but did not establish that she played the required number of matches.

The Court therefore found an intelligible basis for distinguishing her from those who qualified, rejected the claim of discrimination under Articles 14, 15 and 16, and found Pradeep Singh inapplicable because there had been no approval or assurance of promotion in her case.

Pending applications, if any, were also disposed of.