Knowledge of Prior Marks by Interview Committee Does Not Vitiate Promotion Process Absent Evidence of Mala Fides

The Petitioners, employees of Respondent No. 1 (a public sector insurance company), challenged the Promotion Policy for Officers-2006 and its subsequent amendments.

Petitioner No. 1 (Manager, Scale IV) and Petitioner No. 2 (Assistant Manager) alleged that the policy was designed to favor "pre-identified" candidates and facilitate corruption.

They specifically challenged the Interview Committee’s access to written marks and APAR scores prior to interviews, the relaxation of criteria for SC/ST candidates in higher scales, and the provision of pre-promotion training to OBC candidates.

The Respondents contended that the policy was valid, the Petitioners had previously benefited from it, and Petitioner No. 1 failed the written test, making several grievances moot.

1. Whether the Interview Committee’s prior knowledge of candidates' written test scores and APAR marks renders the promotion process arbitrary or mala fide.

2. Whether Rule 14A(e) and (f) regarding relaxation for SC/ST candidates and the restriction of Fast Track Channel vacancies are unconstitutional.

3. Whether providing pre-promotion training and paid leave to OBC candidates is legally permissible in the absence of reservation in promotions for the OBC category.

The Court applied Article 226 of the Constitution of India regarding writ jurisdiction and Article 335 concerning the claims of Scheduled Castes and Scheduled Tribes to services and posts.

Principles of administrative law regarding mala fides and the burden of proof, noting that allegations of manipulation must be supported by cogent evidence.

The Court referenced Ashok Kumar Yadav v. State of Haryana (1985) and Paramjit Singh v. IOCL to distinguish between cases where prior knowledge of marks might indicate bias versus structured institutional policies.

The Court found that the Petitioners failed to substantiating claims of corruption or manipulation with evidence.

It reasoned that mere knowledge of written scores or APAR marks by an Interview Committee does not ipso facto establish bias or the ability to "fix" results, especially since the methodology for mark conversion was transparently available.

Regarding Rule 12.2, the Court held that the dual role of the Interview Committee as the Promotion Committee is not unconstitutional absent a showing of prejudice or conflict of interest.

On the issue of relaxations, the Court determined that a 10% relaxation for SC/ST candidates is a valid welfare measure under Article 335.

It further held that Rule 14A(f) was a reasonable mechanism to balance seniority with merit and that Petitioner No. 1’s failure in the written test meant the rule did not cause him personal prejudice.

The court ruled that pre-promotion training for OBCs is a legitimate welfare activity and not a prohibited statutory interference.

The Court dismissed the Writ Petition and all pending applications, finding no merit in the challenge to the policy's validity or the conduct of the 2022 Promotion Exercise. Any interim protection previously granted was effectively vacated.