Seniority lists finalized before the N.R. Parmar judgment cannot be revised using its subsequently overruled principles.

The applicant was appointed as an Income Tax Inspector in Bombay on March 4, 1991, and subsequently transferred to the Jaipur (Rajasthan) charge on her own request, joining on October 4, 1992

Following a series of litigations regarding her seniority, the Rajasthan High Court directed the respondents on July 9, 2015, to finalize the seniority list in light of the Supreme Court's decision in Union of India v. N.R. Parmar

Consequently, a Rajasthan cadre seniority list for Income Tax Officers (ITOs) was published on July 30, 2015, placing the applicant at Sl. No. 177

However, the All India seniority list of ITOs published on September 1, 2015, failed to incorporate the revised Rajasthan list

The respondents argued that the All India list was finalized as of January 1, 2012, and that the subsequent overruling of N.R. Parmar by the Supreme Court in K. Meghachandra Singh (2019) meant the N.R. Parmar principles applied only prospectively to lists drawn between November 2012 and November 2019

Whether the respondents were legally bound to rectify the All India seniority list dated September 1, 2015, to reflect the Rajasthan cadre seniority list dated July 30, 2015, which was drawn based on the now-overruled N.R. Parmar ratio

The Tribunal applied the principles governing inter-se seniority between direct recruits and promotees as settled by the Supreme Court.

It specifically relied on K. Meghachandra Singh Ors. v. Ningam Siro Ors. (2019), which overruled Union of India v. N.R. Parmar (2012)

The core rule established in K. Meghachandra is that seniority cannot be claimed from a date before an incumbent is "borne in the cadre" (i.e., the date of appointment) and that the N.R. Parmar decision applies only prospectively

The Tribunal also referenced the principle that when a law is declared "bad," efforts should be made to avoid its propagation in pending seniority determinations

The Tribunal analyzed the chronology of the seniority lists and the applicable law.

It noted that the All India seniority list of ITOs was reckoned as of January 1, 2012

Crucially, the N.R. Parmar judgment, which allowed seniority to be backdated to the year of the recruitment process initiation, was delivered on November 27, 2012—after the effective date of the All India list

The Tribunal reasoned that because the All India list pertained to a period prior to N.R. Parmar, the applicant could not demand the retroactive application of its principles

Furthermore, the K. Meghachandra decision mandated that N.R. Parmar be applied prospectively and protected only those seniority lists already finalized based on that ratio during its period of validity (2012–2019)

Since the respondents had already cancelled the July 30, 2015 Rajasthan list and the All India list was pegged to the 2012 status, the Tribunal found no legal grounds to interfere

The applicant's claim for rectification based on a subsequently cancelled cadre list was rejected

The Original Application was dismissed as being devoid of merit, with no order as to costs