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Issues Involved:
1. Interpretation of "seniority-cum-merit" criterion for promotion. 2. Validity of promotion processes followed by various Regional Rural Banks. 3. Compliance with the prescribed rules and principles of "seniority-cum-merit". Detailed Analysis: 1. Interpretation of "Seniority-Cum-Merit" Criterion for Promotion: The main issue in these appeals is the interpretation of the "seniority-cum-merit" criterion prescribed for promotion to the post of Area Manager/Senior Manager in Regional Rural Banks under the Regional Rural Banks (Appointment & Promotions of Officers and Other Employees) Rules, 1988. The criterion of "seniority-cum-merit" emphasizes seniority, provided the candidate has the minimum necessary merit requisite for efficiency of administration. The senior, even though less meritorious, shall have priority, and a comparative assessment of merit is not required. 2. Validity of Promotion Processes Followed by Various Regional Rural Banks: The appeals are categorized into two groups: Andhra Pradesh and Madhya Pradesh. The Andhra Pradesh group involves Rayalaseema Grameena Bank and Pinakini Grameena Bank, while the Madhya Pradesh group involves Baster Kshetriya Gramin Bank, Rewa Sidhi Gramin Bank, and Chhindwara-Seoni Kshetriya Gramin Bank. Rayalaseema Grameena Bank: - 1988 Promotions: Promotions made on May 3, 1988, were challenged belatedly in 1993. The High Court dismissed the challenge due to laches, and the Supreme Court upheld this decision, noting that the promoted officers had acquired rights to seniority. - 1989 Promotions: The promotion process laid down in September 1989 was found to be contrary to the principle of "seniority-cum-merit" as it involved awarding marks for seniority, qualifications, interview, and performance, with more than 50% marks for interview and performance. The High Court's decision to quash these promotions was upheld by the Supreme Court. Pinakini Grameena Bank: - 1992 Promotions: The promotion process involved awarding marks for seniority, qualifications, performance, and interview. The High Court found this method to be contrary to the principle of "seniority-cum-merit" as it virtually amounted to "merit-cum-seniority." The Supreme Court upheld the High Court's decision. Baster Kshetriya Gramin Bank: - 1993 Promotions: The selection was based on marks assigned during interviews, which was not in consonance with the principle of "seniority-cum-merit." The High Court's decision to quash these promotions was upheld by the Supreme Court. Rewa Sidhi Gramin Bank: - 1989 Promotions: The promotion policy involved awarding marks for seniority, qualifications, performance, and interview, with candidates needing to secure a minimum of 40% marks in the interview. The High Court found this method to be contrary to the principle of "seniority-cum-merit." The Supreme Court upheld the High Court's decision. Chhindwara-Seoni Kshetriya Gramin Bank: - 1993 Promotions: The selection process involved prescribing minimum qualifying marks for the interview, and those who met this standard were selected based on seniority. The Supreme Court found this method to be in accordance with the principle of "seniority-cum-merit" and set aside the High Court's decision, affirming the promotions. 3. Compliance with the Prescribed Rules and Principles of "Seniority-Cum-Merit": The Supreme Court emphasized that the criterion of "seniority-cum-merit" does not involve a comparative assessment of merit but requires assessing the minimum necessary merit for efficiency. The competent authority can lay down the minimum standard and prescribe the mode of assessment, such as performance appraisal and interview, but promotions should be based on seniority once the minimum standard is met. Conclusion: The Supreme Court upheld the High Court's decisions in most cases, except for the Chhindwara-Seoni Kshetriya Gramin Bank, where the promotion process was found to be in accordance with the principle of "seniority-cum-merit." The appeals challenging the promotions in Rayalaseema Grameena Bank (1988), Pinakini Grameena Bank, Baster Kshetriya Gramin Bank, and Rewa Sidhi Gramin Bank were dismissed, while the appeal related to Chhindwara-Seoni Kshetriya Gramin Bank was allowed.
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