Ineligible employee lacks locus standi to challenge promotion of subordinates granted relaxation in experience qualifications.

In September 2008, applications were invited for the post of Senior Permanent Way Supervisor (Sr.PWS) under a 25% Limited Departmental Competitive Examination (LDCE) quota, requiring 3 years of regular service

On May 7, 2009, a corrigendum was issued relaxing the service requirement to 1 year for reserved category candidates

The private respondents applied under this relaxation, passed the written examination with 60% marks, and were promoted in 2010

In 2012, the Petitioner—who admittedly did not meet the original 3-year service requirement and was ineligible for the relaxation—challenged these promotions

After a remand from the High Court, the Central Administrative Tribunal (CAT) dismissed the Petitioner's application

The Petitioner approached the High Court via this Special Civil Application.

1. Whether an employee who is himself ineligible for a promotional post has the locus standi to challenge the promotion of other candidates

2. Whether long-standing promotions (exceeding 16 years) should be set aside on the grounds that the relaxation of eligibility criteria was unauthorized

The Court applied the settled principle of locus standi in service jurisprudence, which dictates that only an eligible candidate can challenge a recruitment process

the Three-Judge Bench decision in Pankjeshwar Sharma Ors. v. State of Jammu and Kashmir Ors. (2021) 2 SCC 188, which held that Article 14 does not envisage "negative equality"; thus, even if a state makes a mistake in an appointment, it cannot be forced to perpetuate that mistake by appointing another ineligible person

The Court distinguished Lakhi Ram v. State of Haryana regarding cadre-interest

The Court distinguished Smt. Ravinder Sharma v. State of Punjab regarding educational qualifications

The Court reasoned that the Petitioner suffered from an "inherent ineligibility" as he lacked the requisite three-year work experience and did not qualify for the reserved category relaxation

Consequently, he had no legal right to be considered for the post and therefore could not be "aggrieved" by the selection of others

the private respondents possessed the necessary educational qualifications and had cleared the competitive exam without mark concessions

Even if the corrigendum regarding service duration was technically unauthorized, the Court held that after 16 years of service, it would be "grossly unfair" to disturb the respondents' positions, especially at the behest of an ineligible challenger

The High Court dismissed the petition and discharged the rule

The Court affirmed that long-standing appointments (16 years) should not be unsettled, particularly when the incumbents are near the end of their service and no wrongdoing is attributed to them

All pending civil applications were consigned to the record