State Bank of India cannot deny PwD candidates relaxed benchmarks for direct placement while extending them to SC/ST candidates.

The Petitioners, Persons with Benchmark Disabilities (PwD), were recruited as Probationary Officers by the State Bank of India (SBI) in 2018.

Per Circular No. CDO/STU-TRAINING/3/2019-20, a continuous assessment of 1000 marks governed both confirmation in Junior Management Grade Scale-I (JMGS-I) and direct placement in Middle Management Grade Scale-II (MMGS-II).

For confirmation, SBI allowed a 5% relaxation (45% vs 50%) to both SC/ST and PwD candidates.

However, for MMGS-II placement, the 5% relaxation (70% vs 75%) was extended only to SC/ST candidates, excluding PwDs.

The Petitioners scored above 70%, qualifying them for confirmation but falling short of the 75% unrelaxed benchmark for MMGS-II.

1. Whether the court has territorial jurisdiction and whether the petitions are barred by delay or acquiescence.

2. Whether SBI could legally grant a 5% relaxation to SC/ST candidates for MMGS-II placement while denying the same to PwD candidates within the same assessment policy.

3. Whether Article 335 of the Constitution or Section 34 of the RPwD Act, 2016 justifies the exclusion of PwDs from the relaxed benchmark.

Article 14 of the Constitution (Right to Equality) and the Rights of Persons with Disabilities (RPwD) Act, 2016, emphasizing the duty of the State to provide equal opportunity and remove barriers in service.

Anamol Bhandari v. Delhi Technological University and Aryan Raj v. Chandigarh Administration, which established that PwD candidates are entitled to the same relaxation as SC/ST candidates in the absence of a rational basis for differential treatment.

The proviso to Article 335 (allowing lower standards for SC/STs in promotions) is an enabling provision and not a prohibition against extending similar concessions to PwDs.

The Court clarified that the MMGS-II movement was a "placement/fitment" route embedded within the confirmation process, not a standard promotion.

It found SBI’s reasoning—that no government mandate existed for PwD relaxation in this specific grade—flawed because SBI had voluntarily 5% relaxation to SC/STs under its own policy.

The Court noted that SBI itself applied the 5% relaxation to PwDs for confirmation, proving that such a concession did not inherently undermine administrative efficiency.

Since SC/ST and PwD candidates are both protected classes facing systemic disadvantages, denying parity in the relaxed benchmark without a rational nexus to the object of leadership suitability was held to be discriminatory and arbitrary.

The Court ordered SBI to: (i) treat Petitioners as having met the MMGS-II benchmark; (ii) grant notional placement in MMGS-II from the date their batchmates were placed; (iii) refix seniority and pay notionally; and (iv) release differential monetary benefits within twelve weeks.

Per an earlier undertaking, Petitioners are to be permitted to participate in the next promotional exercise for MMGS-III with consequential benefits from the 2024–25 promotion year.