Failure to meet prescribed promotion benchmarks disentitles an employee to a time-bound pay scale.

The appellant, an employee of the respondents, became eligible for consideration for a third time-bound pay scale on completing 30 years of qualifying service on 1 August 2018.

A scrutiny committee assessed his service record for 2008–2018 and awarded him 9 marks, below the prescribed minimum of 10. The respondents therefore denied the benefit.

The appellant challenged that decision in a writ petition, which the Single Judge dismissed on 18 March 2026; he then filed this writ appeal under Section 2(1) of the Madhya Pradesh Uchcha Nyayalaya (Khand Nyaypeeth Ko Appeal) Adhiniyam, 2005.

He argued, among other things, that adverse ACRs had not been communicated and that the qualifying criteria had not been disclosed to him.

Whether the appellant was entitled to the third time-bound pay scale despite receiving 9 marks against the prescribed minimum of 10.

Whether the denial of the benefit was unlawful because the relevant ACRs or qualifying criteria had not been communicated to the appellant.

The Finance Department Notification dated 6 April 2018 governs the grant of time-bound pay scales and requires compliance with the procedure applicable to promotion, including evaluation of ACRs and satisfaction of minimum qualifying marks.

The appellant relied on R.K. Jibanlata Devi v. High Court of Manipur, 2023 SCC OnLine SC 178, in support of his submission that an uncommunicated grading should not be relied on to deny service benefits; however, the Court did not expressly apply or discuss that precedent in its reasoning.

The Court accepted that the appellant had completed 30 years of qualifying service and was eligible for consideration, but held that eligibility did not dispense with the notification’s prescribed assessment procedure.

The committee assessed the appellant’s service record for the relevant ten-year period and awarded 9 marks, one below the required benchmark.

The Court found the assessment fair, noted no mala fides, and found no illegality either in the respondents’ decision or in the Single Judge’s order. It did not separately elaborate on the appellant’s communication-based objections.

It dismissed the writ appeal and made no order as to costs.