Specific location classifications in promotion policies must be strictly construed according to the primary policy's text.

The respondent, an Inspector Grade-I posted at the Chandernagore Branch under Calcutta Division-XV, participated in a promotion process for the cadre of Assistant Administrative Officer (AAO)

The appellants (National Insurance Co.) disqualified him on the ground that he failed to meet the minimum premium procurement targets of ₹8 lakhs in the preceding year and a ₹6-lakh average over the preceding three years

The insurance company argued that since Chandernagore falls within the "Calcutta Urban Agglomeration" and the respondent receives a City Compensatory Allowance (CCA), he must meet the higher targets set for the metropolitan city of Calcutta

The writ court, via order dated 16.09.1986, set aside this disqualification and directed the appellants to consider his promotion based on the lower targets applicable to "A Class Cities"

Whether the respondent’s eligibility for promotion should be governed by the premium procurement targets of the four metropolitan cities (Serial A) or the targets for "A Class Cities" (Serial B) under Clause 11(c) of the Promotion Policy

Clause 11(c) of the "Promotion Policy for Promotion of Inspector Grade-I to the cadre of Assistant Administrative Officer," which establishes a tiered table of premium targets based on the area of operation

Clarificatory Circular dated 25.01.1980, which defines "A, B-1, and B-2 Class Cities" as those declared by the Central Government for the payment of City Compensatory Allowance (CCA) to its employees

The Court noted that the Promotion Policy creates a clear categorical distinction between four specific metropolitan cities—Bombay, Calcutta, Madras, and New Delhi (Serial A)—and other "Class Cities" (Serial B)

The Court reasoned that the language of the Table is unambiguous: Serial A applies strictly to the named cities, which are not interchangeable with surrounding suburban areas

The Court rejected the appellants' argument regarding "Urban Agglomeration," stating that such a concept is extraneous to the Promotion Policy, which contains no provision linking census-based agglomerations to premium targets

Since the respondent was posted in Chandernagore and received a CCA, he fell under Serial B ("A Class Cities"), which mandates a lower target of ₹6 lakhs in the preceding year and a ₹4.5-lakh average over three years—targets which the respondent had admittedly met

It held that the respondent was entitled to be considered for promotion using the eligibility criteria for "A Class Cities" rather than the higher Calcutta metropolitan targets

The Court directed that the respondent’s claim for promotion and consequential benefits be pursued in light of these findings