Promotion quotas proportionate to feeder-cadre strength are valid absent demonstrated arbitrariness.

The petitioner, a Technical Assistant, challenged the Recruitment and Promotion Rules notified on 26 October 2009, which replaced the earlier Rules dated 9 June 1977.

The Rules allocated 25% of the 12 District Controller posts to direct recruitment and 75% to promotion; of the promotional quota, 50% was assigned to Food and Civil Supplies Officers, 20% to Superintendents Grade-II, and 5% to Technical Assistants.

The petitioner contended that the Technical Assistant quota was discriminatory and that the roster placed the category’s turn at the 19th position.

The State relied on the respective feeder-cadre strengths—17, 15, and 1—and defended the allocation as a policy decision.

The petition sought, among other relief, quashing of the 2009 notification.

Whether allocating 5% of the promotional quota to Technical Assistants, compared with 50% and 20% for the other feeder categories, was arbitrary or discriminatory.

Whether placing the Technical Assistant category at the 19th position in the roster rendered the Rules or roster unlawful.

The prescription of service conditions, including promotional avenues and eligibility criteria, falls within the State’s policy discretion, subject to constitutional limitations; courts ordinarily will not substitute their views for the State’s absent arbitrariness or other constitutional infirmity (P.U. Joshi v. Accountant General, Ahmedabad, 2003 (2) SCC 632).

A public employee has no fundamental right to promotion, but has a right to be considered for promotion when a vacancy exists and the employer initiates the promotion process (Ajit Singh v. State of Punjab, (1999) 7 SCC 209).

The Court found that the petitioner had not rebutted the State’s pleaded cadre strengths.

It accepted that the allocation reflected the relative strengths of the feeder categories, with the larger categories receiving larger promotional shares, and found no arbitrariness in assigning 5% to a category with one post.

It also found no demonstrated violation in the roster: the petitioner had not shown that its sequence conflicted with another applicable notification or regulation.

Applying the principle of judicial restraint over service-policy decisions, the Court declined to interfere.

It dismissed the writ petition and disposed of any pending miscellaneous applications.