The Supreme Court of India held that judicial officers who successfully qualified for the suitability test for promotion under the 65% promotional quota could not be denied promotion based solely on merit list placement. Notional promotions were granted with consequential service benefits except back wages.

Judicial officers who passed the suitability test are entitled to promotion and seniority from the date other officers in the same batch were promoted. The High Court's decision to prioritize a merit list over suitability criteria was overturned.

Acts and Sections Discussed:

1. Constitution of India: Article 233 - Appointment of district judges.
2. Jharkhand Superior Judicial Services (Recruitment, Appointment, and Condition of Service) Rules, 2001: Rules 4 and 5 concerning promotion and recruitment criteria.

1. Case Background (Paras 1-3):

• Appellants challenged the notification promoting juniors to District Judges based on merit-list placement despite qualifying suitability tests.
• The High Court dismissed their writ petition, favoring the merit-based selection approach.

2. Relevant Rules and Criteria (Para 3):

• Appointment quotas: 65% promotion on merit-cum-seniority, 10% through limited competitive examination, and 25% via direct recruitment.
• Suitability test scoring details provided, requiring at least 40 marks for qualification.

3. Key Precedents (Para 4):

• Reference to Ravikumar Dhansukhlal Maheta case, emphasizing that suitability tests are distinct from competitive examinations.
• Promotions should be granted upon suitability, not relative merit.

4. Supreme Court Observations (Para 5):

• Denial of promotion to qualified candidates due to merit-list ranking violates the 65% quota's purpose.
• Subsequent promotions of appellants necessitate retrospective seniority alignment.

5. Conclusion and Relief (Paras 6):

• High Court orders set aside.
• Appellants granted notional promotions and service benefits, excluding back wages.

Ratio Decidendi:

Suitability for promotion under the 65% quota should be determined on an individual basis, without comparative assessment through merit lists. Deprivation of promotion to qualified candidates undermines the principles of merit-cum-seniority.

Subjects:

Judicial Services Promotion and Seniority Disputes.
Promotion, Seniority, Suitability Test, Judicial Services, Jharkhand, Supreme Court Judgment, Merit-cum-Seniority.