Promotional relief for stagnating employee sustained despite narrow bye-law construction and limited Article 136 interference.

The Supreme Court discussed promotional relief for a stagnating employee and noted that the promotional bye-law, properly construed, applied only to officers engaged in scientific work and not to administrative staff. Even so, it declined to interfere with the Tribunal's grant of relief because the employee had remained without promotion for about twenty years under a defective promotional policy, and the case did not disclose manifest injustice warranting correction under Article 136. The Court also stressed the limited scope of interference in service matters and the finality-oriented scheme of the Administrative Tribunals Act, 1985, including the Tribunal's guided procedure and exclusion of ordinary court jurisdiction.

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Issues: Whether the Tribunal's order granting promotional relief to a stagnating employee could be sustained despite the Court's disagreement with the Tribunal's construction of the promotional bye-law.

Analysis: The promotional bye-law applied only to officers engaged in scientific work and did not extend to staff in the administrative category. The Court, however, declined to disturb the relief because the employee, though highly qualified, had remained without promotion for about twenty years due to a defective promotional policy. In service matters, the Court emphasized the limited scope of interference under Article 136 of the Constitution of India, particularly where the Tribunal has rendered substantial justice and no manifest injustice calls for correction. The scheme of the Administrative Tribunals Act, 1985, including the Tribunal's guided procedure, finality of orders, and exclusion of ordinary court jurisdiction, reinforced the approach of restraint.

Conclusion: The Tribunal's relief was upheld and the appeal was not allowed.

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