Roster point reservation applies only from the date a cadre achieves plurality of posts.

The petitioner, a Station Officer belonging to the Scheduled Caste (SC) category in the Puducherry Fire Services Department, challenged the Central Administrative Tribunal’s (CAT) refusal to grant him promotion to the post of Additional Divisional Fire Officer (ADFO).

The petitioner contended that as per the Office Memorandum (OM) dated 02.07.1997, the 7th point in the post-based roster was reserved for SC candidates, and all prior appointments since the cadre's inception should be counted to determine this point.

The respondents argued that the ADFO post was a single-post cadre until 1997, during which time rosters could not legally apply.

They maintained that the post-based roster only commenced when the cadre became plural in 1997, making the 2015 vacancy an unreserved point based on merit.

1. Whether the post-based roster for reservation must be calculated by counting all appointments from the date of inception of the cadre, even if the post was originally a single-post cadre

2. Whether the reservation roster can be applied to a single-post cadre through the device of rotation

The Court applied the principles of post-based reservation rosters as outlined in the Office Memorandum dated 02.07.1997.

It primarily relied on the Constitutional Bench decision in Post Graduate Institute of Medical Education & Research v. Faculty Assn. (1998) 4 SCC 1, which established that reservation—including the device of a rotating roster—cannot be applied to a single-post cadre as it would result in 100% reservation and exclude merit-based candidates from other segments of society.

The Court also referenced R.K. Sabharwal v. State of Punjab regarding the transition from vacancy-based to post-based rosters.

The Court analyzed Clause 5 and Annexure-I of the 1997 OM, noting that while it suggests adjusting existing appointments into the new roster, this instruction must be read in the context of "plurality of posts".

The Court reasoned that since the ADFO post was a singular post until 1997, applying the petitioner's logic (counting all previous holders to trigger an SC reservation at the 7th vacancy) would effectively force a reservation onto a post that was legally exempt from reservation during those years.

Following the Post Graduate Institute precedent, the Court held that the roster could only legitimately begin operating from the point the cadre became plural.

Therefore, the Department was correct in ignoring the appointments made during the "single-post" era and starting the roster calculation from 1997 onwards.

Under this calculation, the 2015 vacancy did not fall under the SC reserved point.

The Court confirmed that the respondents correctly applied the roster from the date the posts became plural.

The High Court upheld the Tribunal's order and dismissed the Writ Petition, concluding that the petitioner was not entitled to the promotion under the 7th roster point as claimed.

No costs were awarded.