Seniority under service rules follows examination rank, and settled gradation lists cannot be reopened by later administrative notes.

Service rules framed under Article 309 governed intra-batch seniority by the rank secured in the prescribed final examination, not merely by the date of appointment. The Court noted that this rule applied to the relevant ranger training structure and that later administrative steps could not unsettle seniority already recognised in gradation lists. It further accepted that changes in course structure had made the literal training provisions impracticable, so the State's one-year and two-year training arrangement operated as a practical implementation of the rules rather than a basis to disturb settled seniority. The earlier administrative determination had attained finality, and the later note was inconsistent with the governing rules.

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Issues: Whether the inter-se seniority of the two batches of Range Forest Officers was to be governed by the date of appointment or by the rules governing seniority, and whether the later governmental note and resolution could unsettle the seniority already recognised in the gradation lists.

Analysis: The service rules framed under Article 309 provided that appointment to the post of Ranger followed successful completion of the prescribed training, while seniority under Rule 14 of the 1969 Rules and Rule 22 of the 1974 Rules was linked to the respective ranks obtained in the final examination at the Rangers College, irrespective of the date of joining service. The Court held that these provisions governed intra-batch seniority and did not justify reversing the settled position between two batches that had different qualifications, different training periods, and different dates of appointment. It further held that the governmental decision of 12.10.1982 and the subsequent gradation lists had attained finality, and that the later note of 29.09.1993 was contrary to the governing rules. Applying a purposive construction, the Court accepted that the training provisions had become unworkable in their literal form because of changes in course structure, and that the State's arrangement of one-year training for graduates and two-year training for non-graduates was a sensible implementation of the rules rather than a basis for disturbing seniority.

Conclusion: The inter-se seniority of the 1980-81 graduate batch above the 1979-81 non-graduate batch was upheld, and the challenge to the governmental action unsettling that seniority failed.

Ratio Decidendi: Where service rules fix seniority by the rank secured in the prescribed final examination, settled seniority cannot be displaced merely because batches underwent different training periods or joined service on different dates, especially when the earlier administrative determination has attained finality.

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