Inclusion in a contingency list creates no vested promotion right absent a qualifying vacancy during its validity.

The petitioner, an LIC employee, sought promotion to Higher-Grade Assistant (Programmer-II) from Assistant/Cashier.

In the 2013–14 promotional exercise, his name was placed on the contingency list dated 10 February 2014.

He claimed that a vacancy arising on 7 July 2014 should have been filled from that list. The information obtained through RTI, however, showed that the vacancy was in PG-I, not PG-II; the PG-I post was filled by promoting an employee from PG-II.

The petitioner filed this writ petition in 2016, seeking promotion with retrospective effect. The parties exchanged affidavits.

1. Whether the petitioner’s inclusion in the 2013–14 contingency list entitled him to promotion to PG-II when the vacancy arising during the list’s currency was in PG-I.

2. Whether the petitioner could claim consideration against a consequential PG-II vacancy arising from the promotion to PG-I, despite no identified rule requiring that sequence of promotions.

3. Whether delay and laches warranted refusing the requested relief.

Under Rule 6(4) of the Life Insurance Corporation of India Class III and Class IV Employees (Promotion) Rules, 1987, the ranking list remains in force for one year.

Inclusion in a contingency list does not create a vested or indefeasible right to promotion; it preserves candidature for consideration only if a qualifying vacancy arises in the relevant promotional cadre while the list remains operative and in accordance with the governing rules.

An employee has a right to consideration for promotion when the occasion arises, but no right to insist on promotion or on the creation of a vacancy through a particular sequence of promotions.

The Court also applied the principle that delay is not invariably fatal, but may bar relief where circumstances have changed or a settled position would be unsettled.

It considered Ajit Singh v. State of Punjab and Ajay Kumar Shukla v. Arvind Rai on the right to consideration, and distinguished Oriental Insurance Co. Ltd. v. T.S. Sastry, which concerned an additional post created during the currency of the list.

The petitioner’s contingency-list candidature was conditional on a vacancy arising in PG-II during the list’s one-year validity.

The vacancy identified by the RTI material arose in PG-I, and the petitioner did not establish that a qualifying PG-II vacancy arose during that period or that the list’s validity was extended.

Nor did the rules require LIC to promote an employee through a sequence that would generate a consequential PG-II vacancy for the petitioner.

The Court further noted that subsequent promotional exercises had taken place and that the petitioner had participated in a later process, making belated intervention liable to unsettle the position.

The authorities cited by the petitioner did not establish an entitlement to the relief sought.

The writ petition was dismissed, with no order as to costs.