Promotion decisions warrant judicial restraint absent proof of mala fides, arbitrariness, or material irregularity.

The Appellant joined the State Bank of India as a Clerk-cum-Typist in 1983 and served for over 35 years.

He was not promoted from MMGS-II to MMGS-III in 2017 and filed W.P.(C) No. 7578/2017.

By judgment dated 31 January 2018, the High Court directed the Bank to consider him for back-dated promotion for 2016-17 and 2017-18, subject to his fulfilling the applicable eligibility criteria, including undertaking a written examination and appearing for an interview.

The Appellant participated in the 2018-19 promotion exercise, but his name was not included in the final promotion list dated 15 May 2018.

His subsequent writ petition challenging the promotion process was dismissed by the learned Single Judge on 2 April 2026, leading to the present intra-court appeal.

Whether the Bank’s 2018-19 promotion exercise was vitiated by mala fides, arbitrariness, discrimination, or material irregularity resulting in denial of the Appellant’s promotion.

Whether the Appellant could challenge the requirement of undertaking a written test after the earlier judgment had expressly directed his consideration for promotion subject to his undertaking the written test and appearing in the interview.

Whether the Bank’s failure to disclose the Appellant’s appraisal marks for 2018-19 invalidated the promotion process.

In promotion matters, judicial review is limited; courts do not sit in appeal over the comparative assessment of candidates and may interfere only where the process is vitiated by mala fides, arbitrariness, or material irregularity.

Allegations of mala fides must be established through cogent and credible material and cannot rest on conjecture or surmise.

An employee has a right to be considered for promotion, but no enforceable right to promotion unless the applicable eligibility criteria are fulfilled.

The earlier judgment dated 31 January 2018 required the Appellant to undertake the written examination and appear in the interview as a condition for consideration for back-dated promotion.

The promotion assessment comprised appraisal, written examination, and interview, carrying weightages of 40%, 50%, and 10%, respectively.

The Court held that the Appellant produced no credible material showing that the Bank had penalised him for filing the earlier writ petition or had otherwise acted with mala fides; his unsuccessful candidature, by itself, could not establish an unlawful or biased selection process.

The requirement of a written test was consistent with, and expressly mandated by, the earlier judgment, which the Appellant had not challenged.

Having participated in the written test and interview, he could not subsequently assail those requirements merely because he was not selected.

The Court further accepted the Bank’s explanation that the Appellant’s written-test and interview marks—24 and 9—were obtained in the 2018-19 exercise, while his appraisal marks—38.4 and 39—were taken for 2016-17 and 2017-18 because he was being considered for back-dated promotion for those years.

Accordingly, the alleged non-disclosure of separate 2018-19 appraisal marks did not demonstrate any material irregularity.

The Court found that the Appellant had been duly considered for back-dated promotion in accordance with the judgment dated 31 January 2018, but had not demonstrated grounds warranting judicial interference with the promotion assessment.

The appeal was dismissed, the order of the learned Single Judge dated 2 April 2026 was affirmed, and there was no order as to costs.