Madras HC Upholds Head Clerk’s 6-Month Promotion Deferral Despite Juniors’ Shorter Training, Citing Individual Assessments

The petitioner, a Head Clerk at the Sub Court, Villupuram, challenged the Principal District Judge’s memorandum dated 23 January 2024, which deferred her promotion and directed her to undergo six months’ training in civil and criminal procedure before reconsideration

The promotion committee had assessed the petitioner and other eligible staff.

On reassessment, it found that the petitioner lacked adequate knowledge of civil and criminal procedure and had shown no appreciable improvement.

The petitioner contended that requiring her to undergo six months’ training, while other candidates were promoted subject to shorter training periods, was discriminatory.

The respondents stated that the petitioner was subsequently promoted as Sheristadar in May 2025.

Article 226 of the Constitution empowers the High Court to review administrative decisions, but the Court held that it could not reassess the promotion committee’s individualized assessment of candidates’ performance and training needs in the circumstances of this case.

The Court also accepted that the period of training required may differ from candidate to candidate, depending on the committee’s assessment.

The Court considered the petitioner’s claim of unequal treatment alongside the committee’s assessment that she lacked sufficient exposure to civil and criminal procedure and had not appreciably improved on reassessment.

It reasoned that the different training periods reflected individualized assessments by a committee that had interacted with the candidates; the fact that some candidates required 15 days or three months, while the petitioner and three others required six months, did not by itself warrant judicial interference.

The Court therefore declined to substitute its assessment for that of the promotion committee under Article 226.

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