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2026 Supreme(Chh) 33

IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR
SANJAY AGRAWAL, AMITENDRA KISHORE PRASAD, JJ.
Pankaj Kumar Singh S/o Late Shri Kameshwar Singh – Appellant
Versus
Union of India through General Manager, South Eastern Central Railway, Bilaspur – Respondent
WPS No. 1947 of 2026
Decided On : 23-02-2026

Advocates Appeared:
For the Appellant : Vivek Chopda
For the Respondents: Ramakant Mishra, Neeraj Baghel

The court affirmed that promotion must adhere to the specified criteria of 'seniority-cum-merit,' rejecting claims of irregularity in the promotion process based on 'merit-cum-seniority.'

Headnote:(A) Administrative Tribunals Act, 1985 - Jurisdiction - Promotion Policy - Notification No. 214/2025 - Rejection of interim relief for promotion application - The court affirmed the principle of ‘seniority-cum-merit’ being disregarded in favor of ‘merit-cum-seniority’ during promotions, resulting in the interim relief being deemed unwarranted. (Paras 5, 10-14)

(B) Administrative Discretion - Judicial Review - The court emphasized that judicial review does not permit interference with administrative discretion in matters of promotion unless irreparable harm is demonstrated. (Paras 8, 16)

Facts of the case:
The petitioner challenged the CAT's order declining interim relief against a promotion order that favored other employees based on a different criterion than what was stipulated in the governing rules.

Findings of Court:
The rejection of the application for interim relief was upheld, as the CAT found proper adherence to the notification's stipulations.

Issues: The key questions involved the appropriateness of the interim relief sought and adherence to promotion guidelines.

Ratio Decidendi: The court ruled that the CAT correctly assessed the situation where promotion based on 'merit-cum-seniority' was legitimate given the context and that judicial intervention at this stage was premature.

Result: Writ Petition dismissed.

Table of Content
1. background of the petitioner’s challenge. (Para 1 , 2)
2. reliefs sought by the petitioner. (Para 3 , 4)
3. tribunal's consideration of interim relief. (Para 5)
4. petitioner’s legal arguments and claims. (Para 6 , 7)
5. court's review of the understanding of the promotion. (Para 8 , 9)
6. judicial precedents on seniority-cum-merit principle. (Para 10 , 11 , 12)
7. court's ruling on intervention and pending adjudication. (Para 14 , 15)
8. final ruling and directions. (Para 17 , 18)

ORDER :

1. By way of this petition, the petitioner seeks to challenge the order dated 30.1.2026 passed by the Central Administrative Tribunal, Jabalpur (hereinafter referred to as “the CAT, Jabalpur”) in Original Application No.86/2026. By the impugned order, the CAT, Jabalpur has dismissed the application of the petitioner for interim relief seeking a stay on the operation of the order dated 30.12.2025 passed by the Assistant Personal Officer-III, Personnel Department, Divisional Railway Manager Office, South Eastern Central Railway, Bilaspur (CG), whereby, 26 Railway employees were promoted to the post of CCTS and posted to their respective stations.

2. The petitioner has prayed for the following reliefs in the petition :

10.1 An order may be issued directing the learned Tribunal to produce all the records before this Hon'ble Court pertaining to this matter.

10.2 Allow the present petition, quash and set aside the Impugned Order dated 30.01.2026 (Annexure-P/7) passed by the learned Central Administrative Tribunal, Jabalpur, M.P. in O.A. No. 86/2026 whereby the interim relief as prayed for by the petitioner has been rejected by the learned tribunal and consequently allow the interim relief prayed by the petitioner in its Original Application (O.A. No. 86/2026) and stay the effect and operation of Office Order-DPB/1201/2025 dated 30.12.2025 passed by the Assistant Personal Officer-III, Personnel Department, Divisional Railway Manager Office, Bilaspur till final disposal of the OA by the learned Tribunal.

10.3 Any other relief which this Hon'ble Court may deem fit in the facts & circumstances of the case.

10.4 Cost of the petition may also be awarded

3. The petitioner has preferred OA No.86/2026 before the CAT, Jabalpur, assailing the aforementioned order dated 30.12.2025. The petitioner’s primary contention is that as per the governing rules, promotion must be based on the principle of ‘seniority-cum- merit’. However, the Respondent-Railways, in disregard of this mandate, conducted the promotion process on the basis of ‘merit- cum-seniority’ which is directly contrary to Notification No.214/25. The reliefs sought in the said Original Application read as follows :

8.1 That this Hon'ble Tribunal may be pleased to call the entire records pertaining to the case of the applicant.

8.2 That this Hon'ble Tribunal may be pleased to Quash and set aside the impugned Office Order- DPB/1201/2025 dated 30.12.2025 (Annexure-A/3) issued by the Assistant Personal Officer-III, Personnel Department, Divisional Railway Manager Office, South Eastern Central Railway, Bilaspur, C.G.;

8.3 That this Hon'ble Tribunal may be pleased to Declare that the Applicant is entitled to be in the panel for promotion as Chief Commercial cum Ticket Supervisor in Pay Matrix Level-6;

8.4 Pass any other order or direction deemed fit in the interest of justice.

8.5 Cost of the petition be awarded to the applicants.

4. In the said Original Application, the interim relief was also prayed for, which reads as follows :

In view of the above facts and grounds, the Applicant respectfully prays that this Hon'ble Tribunal may be pleased to stay the effect and operation of Office Order- DPB/1201/2025 dated 30.12.2025 passed by the Assistant Personal Officer-III, Personnel Department, Divisional Railway Manager Office, Bilaspur till final disposal of this OA by this Hon'ble Court.

5. During the hearing of the interim application, the CAT, Jabalpur passed the following order on 30.1.2026, after considering

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