High Court Dismisses Employees' Challenge to Maharashtra Jeewan Pradhikaran Promotion Decisions -- Petitioners Fail to Prove Arbitrariness in Departmental Promotion Committee's Seniority-Based Promotions

Sub Category: Bombay High Court Bench: AURANGABAD

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2026-02-15 15:08:13

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Case Note & Summary

Multiple writ petitions were filed by employees of Maharashtra Jeewan Pradhikaran challenging promotion decisions made by the Departmental Promotion Committee (DPC). The petitioners argued that the DPC had acted arbitrarily by promoting employees based solely on seniority without considering individual merit or conducting proper hearings. The High Court examined the promotion policy and DPC proceedings, finding that the DPC had exercised its discretion properly within the framework of the department's rules. The Court held that principles of natural justice do not require individual hearings in DPC proceedings unless there are specific allegations of mala fides, which were not substantiated in this case. The Court emphasized that judicial interference in administrative promotion matters is limited and should only occur when decisions are arbitrary or mala fide. Finding no such arbitrariness, the Court dismissed all writ petitions.

Headnote

The High Court of Judicature at Bombay, Bench at Aurangabad, dismissed multiple writ petitions filed by employees of Maharashtra Jeewan Pradhikaran challenging promotion decisions -- The petitioners contended that the Departmental Promotion Committee (DPC) had acted arbitrarily in making promotions based on seniority without considering individual cases -- The Court held that the DPC has discretion in promotion matters and principles of natural justice do not require individual hearings in DPC proceedings -- The Court found no arbitrariness or mala fides in the DPC's decisions and declined to interfere with the administrative functioning of the department -- The petitions were dismissed with no order as to costs

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Issue of Consideration: The Issue of Consideration was whether the Departmental Promotion Committee's decisions regarding promotions in Maharashtra Jeewan Pradhikaran were arbitrary, violative of principles of natural justice, or required judicial interference

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Final Decision

The High Court dismissed all writ petitions, holding that the Departmental Promotion Committee had not acted arbitrarily and that no interference was warranted with the administrative decisions regarding promotions

2026 LawText (BOM) (02) 72

Writ Petition No. 11916 of 2019, Writ Petition No. 11920 of 2019, Writ Petition No. 12066 of 2019, Writ Petition No. 13733 of 2019, Writ Petition No. 14602 of 2019, Writ Petition No. 15520 of 2019

2026-02-13

Arun R. Pedneker J. , Vaishali Patil-Jadhav J.

2026:BHC-AUG:6571-DB

• Adv. R. P. Bhumkar for the Petitioners • Ms. V. P. Dama, AGP for the State • Adv. Vinod Patil for Respondent Nos. 2 and 3 in WP Nos. 11916/2019, 11920/2019,13733/2019 • Adv. A. G. Vasmatkar for Respondent Nos. 2 and 3 in WP Nos. 12066/2019, 14602/2019 and 15520/2019

Kiran Bhaskarrao Adgaonkar, Shahedmiya Safiulla Patel, Satyanarayan Sandulal Jajure, Arun Vitthalroa Gangawane, Shivaji Sambhaji Mandade, Shridhar Vyankatrao Vishnupurikar, Milind Harijivanrao Choudhari, Ramesh Tatyasaheb Kulkarni, Ashok Sopanrao Kagde, Shaikh Samad Noor Mohamad, Ganpat Prabhu Tagad, Kisan Santoba Deokar, Ramesh Achutrao Bobade, Suresh Nivruttirao Dake, Sopan Chandrabhan Rakh, Pandharinath Sitaram Tidke, Malhari Vitthalrao Deshpande, Sunil Madhukarrao Joshi, Ashok Ganpatrao Shelke, Govind Raosaheb Khose, Syed Yunus Syed Jafar, Abasaheb Sahebrao Dhaye, Laxman Dagduba Hule, Satish Devidasrao Deshmukh, Dnyanoba Nivrutti Pawar, Syed Akhtar Syed Jafar, Krishnakant Sonaji Terkar, Janardhan Ramrao Mundhe, Arvind Manohar Joshi, Pandit Murlidharrao Kendre, Deepak Apparao Jadhawar, Parmeshwar Haribhau Bhise

The State of Maharashtra through its Secretary, Water Supply and Sanitation Department, The Member Secretary, Maharashtra Jeewan Pradhikaran, The Chief Administrative Officer, Maharashtra Jeewan Pradhikaran, The Superintending Engineer and President Circle Committee, Maharashtra Jeewan Pradhikaran, The Superintending Engineer, Maharashtra Jeewan Pradhikaran, Nanded

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Nature of Litigation: Multiple writ petitions challenging promotion decisions in Maharashtra Jeewan Pradhikaran

Remedy Sought

Petitioners sought quashing of promotion decisions and directions for proper consideration of their cases

Filing Reason

Employees alleged arbitrary promotion decisions by Departmental Promotion Committee based solely on seniority without proper consideration

Previous Decisions

No previous decisions mentioned in provided text

Issues

Whether the Departmental Promotion Committee's promotion decisions were arbitrary and violative of principles of natural justice Whether the Court should interfere with administrative promotion decisions of Maharashtra Jeewan Pradhikaran

Submissions/Arguments

Petitioners argued that DPC acted arbitrarily by promoting based solely on seniority without individual consideration Petitioners contended that principles of natural justice required individual hearings before promotion decisions Respondents likely argued that DPC followed established promotion policy and exercised proper discretion

Ratio Decidendi

Departmental Promotion Committees have discretion in making promotions based on seniority and merit -- Principles of natural justice do not require individual hearings in DPC proceedings unless specific allegations of mala fides are substantiated -- Courts should not interfere with administrative promotion decisions unless they are arbitrary or mala fide

Judgment Excerpts

The Court held that the DPC has discretion in making promotions based on seniority and merit The Court found that principles of natural justice do not require individual hearings in DPC proceedings The Court declined to interfere with the administrative functioning of the department

Procedural History

Multiple writ petitions were filed challenging promotion decisions of Maharashtra Jeewan Pradhikaran -- The petitions were heard together -- The High Court examined the promotion policy and DPC proceedings -- The Court dismissed all petitions