In a significant ruling, the Allahabad High Court addressed the issue of revising finalized seniority lists under the U.P. Government Servant Seniority Rules, 1991. The court emphasized that once a seniority list is finalized, the authority responsible becomes functus officio, meaning it has exhausted its power in that matter and cannot revisit or alter the list repeatedly.
Background of the Case
The petitioners began their careers as Junior Grade Clerks in the Secretariat Administration Department in 1990. Through years of service and subsequent promotions, they ascended to the position of Assistant Review Officers in 2005. In 2016, the department initiated a promotion exercise to elevate these officers to the role of Review Officers. This process culminated on June 30, 2016, after receiving the necessary approvals from the U.P. Public Service Commission. Consequently, 144 individuals, including the petitioners, were promoted on July 13, 2016, with retrospective effect from June 30, 2016, and were placed on a two-year probationary period. The determination of their seniority within this cadre was deferred for separate consideration.
Objections and Confirmation of Seniority
Following the promotions, objections arose from the 2013 batch of direct recruits concerning the retrospective effect of the petitioners' promotions. These objections were systematically reviewed and dismissed, leading to the publication of a tentative seniority list on August 5, 2016. Despite multiple rounds of objections and reviews, the seniority list was reaffirmed, with the final version published on August 11, 2022.
Reevaluation and Legal Challenge
Despite the repeated confirmations, the State Government revisited the issue of backdated promotions in 2023. Notices were issued to the petitioners, proposing to adjust their promotion dates from June 30, 2016, to July 13, 2016. The petitioners contested this proposed change, arguing that the promotion process had been appropriately conducted and finalized in 2016. They further contended that the authority lacked the jurisdiction to alter the finalized seniority list after such an extended period.
Court's Analysis and Judgment
The High Court scrutinized the provisions of the U.P. Government Servant Seniority Rules, 1991, particularly focusing on the absence of any clause permitting the review or alteration of a finalized seniority list. The court observed that once a final seniority list is prepared, following the prescribed procedures and after addressing all objections, the authority becomes functus officio. This status implies that the authority has fulfilled its mandate regarding that specific matter and does not possess the power to reexamine or modify the seniority among the same group of individuals repeatedly.
The court further elucidated that granting seniority from a backdate is not inherently illegal or arbitrary, provided such actions are grounded in statutory rules. In this context, the retrospective effect given to the petitioners' promotions was deemed lawful, as it aligned with the established procedures and received the requisite approvals.
Implications of the Judgment
This ruling reinforces the principle of finality in administrative decisions concerning seniority. It underscores that once a seniority list is finalized, it should not be subject to alteration, barring exceptional circumstances explicitly provided for within the statutory framework. This ensures stability and predictability within the administrative structure, preventing potential disruptions that could arise from frequent revisions of seniority standings.
Conclusion
The Allahabad High Court's decision highlights the importance of adhering to statutory provisions and respecting the finality of administrative decisions. By affirming that authorities become functus officio after finalizing seniority lists, the court has set a precedent that safeguards the interests of government servants and upholds the integrity of administrative processes. This judgment serves as a crucial reference for future cases involving disputes over seniority and the permissible scope of administrative reviews.
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