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
| 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
B.V. Sivaiah and Others v. K. Addanki Babu and Others
Rajendra Kumar Srivastava and Others v. Samyut Kshetriya Gramin Bank and Others
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.'
Promotion based on merit must be prioritized over seniority, requiring a comparative assessment of candidates' qualifications and service records.
The principle of 'seniority-cum-merit' requires that promotions must prioritize seniority among candidates who meet a minimum merit standard, and any deviation from this principle renders the promoti....
Promotions must be based on seniority subject to fitness, not solely on merit or ACR grading, as per the applicable rules.
The main legal point established in the judgment is the significance of the seniority-cum-merit principle in the promotion process, as prescribed in the 'Regional Rural Banks (Appointment and Promoti....
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