The State may amend promotion quotas for administrative exigencies absent arbitrariness.

The petitioners were appointed as Junior Engineers (Civil) with diploma qualifications and later regularized; most subsequently obtained engineering degrees while in service

Under the 2019 Recruitment and Promotion Rules, 10% of the promotion quota was reserved for Junior Engineers who acquired a degree during service, while a separate 15% quota applied to those who held a degree when appointed

A 2026 amendment combined these categories into a 29% quota, subject to specified recognition and cut-off requirements for AMIE qualifications

The petitioners challenged the amendment as arbitrary and contrary to Articles 14 and 16, contending that it removed their dedicated quota

The State relied on regulatory changes affecting AMIE recognition and the non-availability of eligible candidates in certain categories as reasons for the amendment

1. Whether the 2026 amendment to the 2019 Rules, combining the separate promotion quotas for degree-holding Junior Engineers, was arbitrary or unconstitutional under Articles 14 and 16

2. Whether the amendment was liable to be set aside despite the State’s stated administrative reasons for changing the promotion structure

The Court applied the principle that prescribing or altering qualifications, eligibility criteria, and promotion avenues is generally within the rule-making authority’s policy domain, subject to constitutional limitations

In P.U. Joshi v. Accountant General, Ahmedabad, (2003) 2 SCC 632, and Chandigarh Administration v. Usha Kheterpal Waie, (2011) 9 SCC 645, the Supreme Court held that courts should not substitute their views for the employer’s on recruitment and promotion criteria where those criteria are rationally connected to the post and are constitutionally valid

State of Jammu and Kashmir v. Triloki Nath Khosa, (1974) 1 SCC 19, and N. Lakshmana Rao v. State of Karnataka, (1976) 2 SCC 502, recognize that service rules may be altered unilaterally by the Government

Mohammad Shujat Ali v. Union of India, (1975) 3 SCC 76, distinguishes a reduction in chances of promotion from an alteration of the right to be considered for promotion

The Court found that the amended Rules did not eliminate the petitioners’ eligibility to compete for promotion.

The former 10% quota for those who acquired degrees during service was consolidated with the 15% quota for degree-holders appointed as Junior Engineers, producing a 29% quota; the Court considered this an overall increase in the relevant accelerated-promotion quota

The petitioners also remained eligible to be considered under the separate 45% promotion quota applicable to Junior Engineers meeting its service requirements

The State’s explanations—including changes in recognition of AMIE qualifications and vacancies arising from the lack of eligible candidates in certain feeder categories—were not shown to be incorrect or pretextual

Applying the settled limits on judicial review of service-rule policy, the Court found no demonstrated arbitrariness or constitutional violation

The writ petition was dismissed, along with any pending miscellaneous applications.