Mandatory recording of reasons for supersession: stock notes do not satisfy the duty or justify reversion.

Regulation 5(5) of the India Police Service (Appointment by Promotion) Regulations, 1955 requires the Selection Committee to record reasons when proposing supersession of a State Police Service officer. A general note stating only that the officer's record was not sufficient for appointment at that stage is not a valid reason, because it does not disclose the material relied on or the rational nexus between that material and the conclusion reached. In the service context, this safeguard supports Articles 14 and 16 by preventing arbitrariness. A stock or mechanical note therefore does not satisfy the duty to give reasons, and a select list based on such a recommendation cannot sustain reversion.

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Issues: Whether the Selection Committee was bound to record reasons under Regulation 5(5) of the India Police Service (Appointment by Promotion) Regulations, 1955 while proposing supersession, and whether the recorded note satisfied that requirement so as to sustain the select list and the appellant's reversion.

Analysis: Regulation 5(5) required the Committee, in the process of selection, review or revision, to record its reasons where supersession of a member of the State Police Service was proposed. The Court treated the requirement as mandatory and held that a mere general formula stating that the officer's record was not sufficient to justify appointment at that stage did not disclose the actual reasons. Reasons had to show a rational nexus between the material considered and the conclusion reached, particularly in a service context where Articles 14 and 16 of the Constitution of India guard against arbitrariness. The impugned note, being only a stock description of the process, did not amount to reasons for supersession.

Conclusion: The select list prepared on the basis of the Committee's recommendation contravened Regulation 5(5) of the India Police Service (Appointment by Promotion) Regulations, 1955 and could not sustain the appellant's reversion.

Final Conclusion: The appellant succeeded, the impugned judgment and reversion order were set aside, and consequential service benefits followed.

Ratio Decidendi: Where a regulation mandates recording of reasons for proposed supersession, a mechanical or stock statement that merely states an overall unsuitability does not satisfy the duty to give reasons; the reasons must disclose a rational nexus between the material considered and the conclusion reached.

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