Quota rule in service seniority prevails over date of entry, with temporary posts and later observations not displacing binding precedent.

Where service rules prescribe recruitment from two sources under a fixed quota, seniority in the cadre must follow that quota and not merely the date of appointment. Promotions made beyond the promotional quota do not confer a superior seniority claim over recruits appointed within their lawful share. The quota arrangement remained operative on the facts discussed, and temporary posts did not take the cadre outside its reach. A later observation about a three-year carry forward period was treated as context-specific and incapable of overriding the binding earlier ruling on the same cadre rules under Article 141. The governing principle was that the quota rule must be strictly applied for appointment and seniority.

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Issues: (i) Whether inter se seniority in the cadre had to be worked out on the basis of the quota rule between direct recruits and promotees. (ii) Whether the quota rule had been abandoned or ceased to operate during the relevant period, and whether temporary posts were outside the cadre for this purpose. (iii) Whether the earlier decisions relied upon justified limiting carry forward of vacancies to three years and displacing the binding effect of the prior ruling governing the cadre.

Issue (i): Whether inter se seniority in the cadre had to be worked out on the basis of the quota rule between direct recruits and promotees.

Analysis: Where recruitment is made from two sources under a prescribed quota, the quota governs not merely initial recruitment but also the fixing of seniority in the gradation list. Promotions made in excess of the promotional quota do not confer a superior claim in seniority over later recruits appointed within their lawful quota. The rule, once operating, requires the available vacancies to be matched to the respective sources according to the prescribed proportions.

Conclusion: Inter se seniority had to be fixed by applying the quota rule, not merely by the date of entry into service.

Issue (ii): Whether the quota rule had been abandoned or ceased to operate during the relevant period, and whether temporary posts were outside the cadre for this purpose.

Analysis: The recruitment rules continued to preserve the quota structure, and later amendments themselves proceeded on that footing. The mere existence of temporary posts did not eliminate the quota arrangement for the cadre. The Court affirmed that the earlier ruling treating temporary posts as outside the cadre for quota purposes remained correct and binding, and rejected the contention that the quota had been given up.

Conclusion: The quota rule continued to apply and temporary posts could not be used to defeat it.

Issue (iii): Whether the earlier decisions relied upon justified limiting carry forward of vacancies to three years and displacing the binding effect of the prior ruling governing the cadre.

Analysis: The observation in the later case about a reasonable three-year carry forward period was context-specific and turned on the special structure of the rules there under consideration. It did not lay down a universal limit applicable to all services. The earlier three-Judge Bench ruling on the same cadre rules remained binding under Article 141 and was not superseded by the later observations. The Court therefore held that the quota rule declared in the earlier decision must be given full effect.

Conclusion: The three-year limitation was inapplicable, and the earlier ruling continued to control the field.

Final Conclusion: The direct recruits were entitled to succeed, the promotee appeals could not be sustained, and the gradation list had to be adjusted in accordance with the quota rule as previously declared.

Ratio Decidendi: Where service rules prescribe a quota between two sources of recruitment, that quota must be strictly observed for seniority as well as appointment, temporary departures do not confer an overriding seniority claim, and later contextual observations in a different case cannot dilute a binding earlier ruling on the same rules.

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