For compulsory retirement, the entire service record remains relevant; recent performance receives greater weight.

The appellant joined the Central Industrial Security Force (CISF) as an Assistant Sub-Inspector on 28 June 1982 and was promoted to Sub-Inspector in 1990 and Inspector in 2003.

Upon attaining 50 years of age, his case was reviewed under Rule 56(j) of the Fundamental Rules.

The Internal Screening Committee found him unfit for continued service, and the Review Committee consequently ordered his compulsory retirement on 6 June 2010.

His representation was rejected by the Representation Committee.

The Delhi High Court dismissed his challenge, holding that his efficiency had declined during the last two years under review and that the compulsory-retirement order was neither arbitrary nor unreasonable.

The appellant thereafter approached the Supreme Court.

Whether the order of compulsory retirement passed under Rule 56(j) was arbitrary, perverse, mala fide, or unsupported by relevant material so as to warrant judicial interference.

Whether the appellant’s entire service record, including adverse material and penalties preceding his promotion as Inspector, could be considered while assessing his suitability for continued retention in service.

Whether greater weight was required to be given to the appellant’s recent service record, particularly his declining performance during the two years preceding compulsory retirement.

The Court applied Rule 56(j) of the Fundamental Rules, under which the Government may compulsorily retire an employee in the public interest on the basis of its subjective satisfaction.

Compulsory retirement is non-punitive and does not attract the principles of natural justice or audi alteram partem.

Nevertheless, judicial review remains available where the decision is mala fide, based on no evidence, arbitrary, capricious, or perverse.

In accordance with Baikuntha Nath Das v. Chief District Medical Officer, the entire service record must be considered, with greater importance ordinarily attached to the record of the later years, while both favourable and adverse material may be weighed.

Relying on Rajasthan State Road Transport Corporation v. Babu Lal Jangir, the Court held that the “washed-off theory,” applicable in certain promotion cases, does not apply when determining whether an employee should be retained in service; earlier adverse entries may therefore be considered, subject to appropriate weight being given to the recent record.

The Court also relied on Posts and Telegraphs Board v. C.S.N. Murthy and Central Industrial Security Force v. HC (GD) Om Prakash, which recognise that a decline in efficiency during the immediate preceding years may justify compulsory retirement under Rule 56(j).

The Court examined the appellant’s service record and found that, although his gradings between 1983 and 2003 fluctuated from “Average” to “Very Good,” and he had received promotions, his performance from 2004 to 2009 showed a significant deterioration.

In particular, his grading declined from “Good” to “Average” during the latter part of 2008 and remained “Average” throughout 2009, immediately before the compulsory-retirement order.

This recent decline was supported by a censure for furnishing a false reason to obtain leave, four warnings for negligence, and two cautions for lethargic conduct.

The Committee was entitled to consider these matters together with the appellant’s earlier service record, notwithstanding his subsequent promotion, because the assessment concerned fitness for continued retention and not eligibility for promotion.

Given the limited scope of judicial review and the appellant’s service in a disciplined and uniformed security force requiring sustained efficiency, vigilance, and discipline, the Court found sufficient relevant material to support the Committee’s subjective satisfaction.

The competent authorities had properly considered the appellant’s entire service record while giving due weight to his declining performance during the immediate preceding years.

The Court upheld the Delhi High Court’s judgment and dismissed the civil appeal as meritless, thereby sustaining the appellant’s compulsory retirement.