Promotion renders challenge to prior adverse APAR entries infructuous if due process was followed.

The applicant, an Additional General Manager at the Ordnance Factory, challenged his Annual Performance Assessment Report (APAR) for the period of 01.01.2012 to 04.08.2012

He was assigned a numerical grading of 6.4 by the Reporting Officer, which was later upgraded to 6.7 by the Reviewing Officer

The applicant alleged that the Reporting Officer acted with bias, recorded adverse entries regarding "team spirit" and "monitoring of output" without merit, and violated Department of Personnel and Training (DOPT) guidelines by failing to complete the mandatory three-month supervisory period before writing the report

The respondents maintained that the grading was objective, based on communicated performance deficiencies regarding delayed executions and lack of coordination

During the pendency of the litigation, the applicant was promoted to the Higher Administrative Grade (HAG) on 04.07.2018

1. Whether the APAR for the period 01.01.2012 to 04.08.2012 was procedurally flawed and vitiated by bias

2. Whether the applicant is entitled to the expunction of adverse remarks and an upgrade of numerical grading to 7.0 for the purpose of further career advancement

3. Whether the Original Application (OA) survived as a live dispute following the applicant's promotion to the HAG Grade

The Tribunal applied the DOPT OM No. 21011/02/2009-Estt. (A) dated 16.02.2009, which establishes the timelines and mandatory procedures for the initiation and completion of APARs

It also relied on DOPT OM No. 22011/5/86–Estt. (B) dated 10.04.1989, which mandates that Departmental Promotion Committees (DPC) should perform an independent assessment of entries in Confidential Reports (CRs) rather than relying exclusively on overall numerical grading

Finally, the court observed the principle that administrative appeals and representations must be decided by reasoned orders

The Tribunal found that the procedural requirements for recording and appealing the APAR were substantially met.

Although the applicant alleged a violation of the three-month supervisory rule, the Tribunal noted that the applicant himself had clubbed the assessment periods and delayed his own self-appraisal submission

The respondents successfully demonstrated that the adverse remarks were not extraneous but were rooted in recorded performance deficiencies previously communicated to the applicant via official advisory

The Tribunal emphasized the "three-tier structure" of the assessment (Reporting, Reviewing, and Accepting Officers) as an institutional safeguard against individual bias

Furthermore, the administrative redressal process was correctly exhausted; the Secretary (Defence Production) and the President of India had reviewed the applicant's representations and issued reasoned orders of rejection

Most significantly, the Tribunal noted that because the applicant had already secured a promotion to the HAG Grade during the litigation, the grievances regarding the 2012 APAR no longer carried practical legal weight

The Tribunal held that the Original Application lacked merit and had been rendered infructuous by the applicant's subsequent promotion to the HAG Grade

The OA was dismissed, and no costs were awarded