State Power to Create Promotional Quotas Based on Educational Qualification and Experience is Legally Valid

The petitioners, graduate Civil Engineers, joined the Karnataka Housing Board ("the Board") as Assistant Engineers (AE) in 2010 and were promoted to Assistant Executive Engineers (AEE) in 2021.

Historically, diploma-holder Engineers could only progress up to the rank of AEE.

On June 1, 2022, the State promulgated the Karnataka Housing Board (Recruitment and Conditions of Service) (Amendment) Rules, 2022, which for the first time created a promotional avenue for diploma-holding AEEs to the cadre of Executive Engineer (EE).

The amendment reserved 75% of EE posts for degree holders (requiring 3 years of service) and 25% for diploma holders (requiring 5 years of service).

The petitioners challenged this amendment and the subsequent common gradation list dated January 22, 2025, arguing it obliterated the distinction between unequals and diluted their promotional prospects.

1. Whether the 2022 Amendment Rules are arbitrary, discriminatory, or violative of Article 14 of the Constitution by treating degree-holders and diploma-holders as equals for promotion to Executive Engineer.

2. Whether the Court can interfere in the policy decision of the State regarding the restructuring of cadres and prescription of promotional avenues.

The Court primarily applied the doctrine of "Reasonable Classification" under Article 14 of the Constitution, holding that educational qualification is a valid basis for classification but does not preclude the State from creating limited channels for different classes.

It relied on P.U. Joshi v. Accountant General, which established that the constitution of cadres and avenues of promotion are matters of exclusive State policy.

Union of India v. Pushpa Rani, which limited judicial review to cases of patent arbitrariness or mala fides.

Dilip Kumar Garg v. State of U.P., which held that if a rule-making authority can bar diploma-holders from promotion altogether, it can certainly choose to grant them restricted promotion.

The Court reasoned that the 2022 Amendment does not merge the two classes but preserves their distinction through separate quotas (75% vs 25%) and differential experience requirements (3 years vs 5 years).

The court found that the legislative intent was to alleviate "career stagnation" among diploma-holders who had spent decades in the service, which is a legitimate administrative objective.

Rejecting the petitioners' argument that degree holders are inherently superior for all high-level functions, the Court held that it cannot sit as an "appellate authority" over executive wisdom regarding technical qualifications.

The Court emphasized that Article 14 does not mandate "mechanical uniformity" across all departments; thus, the fact that other departments do not allow diploma-holders to become EEs is irrelevant to the legality of the Board's specific rules.

The Writ Petition was dismissed, and the impugned Notification dated 01-06-2022 and the Gradation List dated 22-01-2025 were upheld as judicial substitution of policy is impermissible under Article 226.