Finality in seniority disputes prevails: settled service rulings will not be reopened without fresh, compelling material.

The Supreme Court reaffirmed that settled seniority rulings in the Income-tax Service would not be reopened absent fresh, compelling material or other substantial reasons. It held that alleged errors in earlier decisions, non-production of every file, and later materials such as the Rajya Sabha Committee report did not undermine the prior judicial conclusions. Emphasising finality in service disputes, the Court stated that review or reconsideration is exceptional and requires new and important evidence or similarly strong grounds. The challenge to the earlier rulings therefore failed, and no basis was shown to disturb the existing seniority arrangements.

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Issues: Whether the earlier decisions concerning seniority between promotees and direct recruits in the Income-tax Service required reconsideration or review on the ground of alleged errors, non-production of files, later materials, and the petitioners' challenge to the validity and working of the seniority arrangements.

Analysis: The majority held that the request to reopen the settled decisions was unsupported by any fresh and compelling material. It found that the earlier rulings had considered the competing claims carefully, that the Government's inability to produce every file did not make those decisions unsound, and that the later report of the Rajya Sabha Committee on Petitions did not displace the judicial conclusions already reached. The Court emphasized the need for finality in service disputes and stated that review is warranted only in exceptional cases where substantial and compelling reasons, or new and important evidence, justify departure from earlier decisions.

Conclusion: The challenge to the earlier rulings failed, and no ground was made out for their reconsideration; the petitions were rejected as against the petitioners and in favour of the respondents.

Ratio Decidendi: Earlier constitutional or service-law decisions will not be reopened merely because a later challenge asserts error or unfairness; review requires fresh, compelling material or other substantial reasons justifying departure from settled precedent.

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