Eligibility for promotion is determined by stipulated rules; redesignation does not alter promotion avenues.

The applicant, Sazid Khan, working as a Loco-Pilot (Goods), challenged his exclusion from the eligibility list for selection to the post of Chief Loco Inspector (CLI), Electrical, notified by Respondent No. 2 on January 24, 2025.

His name was placed in the ineligible candidates list dated September 3, 2025.

He was further informed on September 15, 2025, that he was ineligible for the written examination because he had not completed 10 years of actual service or 5 lakh km of actual foot-plating experience in eligible feeder Level-6 posts relevant for CLI selection.

The applicant was initially appointed as Diesel/Electric Assistant in 1999 and was promoted to Loco Pilot (Shunting) Grade-I in Level-6 with effect from November 1, 2013, and then to Loco Pilot (Goods) in Level-6 with effect from December 8, 2015.

He contended that his service as Loco Pilot (Shunting Grade-I) in Level-6 should be counted towards the 10-year actual service requirement for CLI selection, citing a re-designation of the post from Sr. Shunting Driver to Loco Pilot (Shunting Grade-I) via RBE No. 29/2004 dated February 13, 2004.

The respondents argued that RBE No. 29/2004 explicitly stated that re-designations would not alter eligibility conditions or avenues of promotion and that the duties of Loco Pilot (Shunting) are distinct from those of Loco Pilots (Goods/Passenger/Mail), whose experience is critical for the supervisory role of a CLI.

Whether the applicant was eligible for selection to the post of Chief Loco Inspector (Electrical) based on his service period, including his tenure as Loco Pilot (Shunting) Grade-I.

Whether the re-designation of Sr. Shunting Driver to Loco Pilot (Shunting) Grade-I under RBE No. 29/2004 entailed a change in the eligibility conditions or avenues of promotion for the post of Chief Loco Inspector.

The court primarily applied the eligibility criteria for Chief Loco Inspector (CLI) as defined by Railway Board letters.

RBE No. 80/2021 dated November 1, 2021, clarified that "10 years of actual service as Loco Pilot" derived from RBE No. 108/2019 dated July 3, 2019.

RBE No. 108/2019 stipulated that only LP (Mail), LP (Passenger), and LP (Goods) who completed 5 lakh kilometers of actual foot-plate duties or 10 years of actual service as Loco Pilots are eligible for CLI selection.

RBE No. 29/2004 dated February 13, 2004, which, while revising designations, explicitly stated that it "will not entail any change inter alia in the pay scales, duties & responsibilities... and eligibility conditions prescribed for the posts or avenues of promotion".

The established legal principle that selection processes must strictly adhere to stipulated procedures without relaxation unless expressly provided in rules and given due publicity was also applied.

The court analyzed the applicant's claim that his service as Loco Pilot (Shunting) Grade-I should be counted towards eligibility for CLI positions.

It noted that the eligibility criteria, as per RBE No. 108/2019 and RBE No. 80/2021, explicitly listed only LP (Mail), LP (Passenger), and LP (Goods) as eligible for CLI selection based on either foot-plate kilometers or 10 years of actual service.

The court found that the "extent guidelines had explicitly provided for consideration of the LP (Mail), LP (Passenger) and LP (Goods) from among the Loco Running staff; and not for LP (Shunting) from among those".

Furthermore, the court referred to RBE No. 29/2004, relied upon by the applicant for re-designation, which clearly stipulated that such re-designation would not change "eligibility conditions prescribed for the posts or avenues of promotion".

This meant that despite the change in nomenclature to "Loco Pilot (Shunting)," the underlying duties, responsibilities, and promotional avenues remained distinct from those of Loco Pilots (Goods/Passenger/Mail).

The court also highlighted the functional difference, noting that Loco Pilot (Shunting) operates within limited yard sections at low speeds, whereas Loco Pilots (Goods/Passenger/Mail) operate trains on open tracks at higher speeds, requiring different experience for the supervisory role of a CLI.

This distinction was crucial for the "critical role of CLIs" who supervise Loco Pilots operating on open railway networks.

The court also found that the Avenue for Promotion Chart (AVC) for Loco Pilot & Loco Inspector of the Mechanical Department did not show CLI as an avenue of promotion directly for Loco Pilot (Shunting) Gr.I.

Consequently, the court concluded that the respondents had correctly applied the uniform eligibility conditions without relaxation to all candidates.

It held that there were no grounds to interfere with the impugned Letter dated September 15, 2025, and the provisional Eligibility List dated September 3, 2025.

The applicant was not entitled to the reliefs prayed for, as his service as Loco Pilot (Shunting) Grade-I was not reckonable for selection as CLI based on extant Railway Board guidelines (RBE No. 108/2019, RBE No. 80/2021) and the explicit statement in RBE No. 29/2004 that re-designation would not alter eligibility conditions or promotional avenues.

The court found the applicant's claim to be untenable and inadmissible on merits.