2014 (12) TMI 1287 - SC - Indian Laws

Railway employees' cooperative society union wins appeal on promotion reservation benefits against contradictory high court ruling

SC allowed appeal by railway employees' cooperative society union regarding reservation benefits in promotions. HC erred by setting aside implementation ... Benefit of reservation to the employees of the society in the matter of their promotion - appeal by South Central Railway Employees Co-Op. Credit Society Employees’ Union - Held that:- Once this Court in SOUTH CENTRAL RAILWAY EMPLOYEES CO-OPERATIVE CREDIT SOCIETY Versus REGISTRAR OF CO-OPERATIVE SOCIETIES [1998 (1) TMI 510 - SUPREME COURT] had decided that the employees of the Society were not entitled to promotion on the basis of any reservation policy, the High Court could not have come to a different conclusion, when the judgment delivered by this Court above was sought to be implemented by issuance of an order dated 12th June, 1998 and the High Court had committed a grave error by setting aside the said order dated 12th June, 1998. If the view taken by the High Court is accepted, in our opinion, there would be total chaos in this country because in that case there would be no finality to any order passed by this Court. When a higher court has rendered a particular decision, the said decision must be followed by a subordinate or lower court unless it is distinguished or overruled or set aside. The High Court had considered several provisions which, in its opinion, had not been considered or argued before this Court when [1998 (1) TMI 510 - SUPREME COURT] was decided. Issues involved:Challenge to judgment of High Court regarding reversion orders based on reservation policy; Interpretation of previous judgment by Supreme Court on reservation policy for promotion; Consideration of relevant factors by High Court in quashing reversion orders; Application of doctrine of per incuriam; Violation of Article 141 of the Constitution of India by lower courts in not following Supreme Court judgment.Analysis:The Supreme Court heard an appeal by a cooperative credit society employees' union against a High Court judgment in a case involving reversion orders issued due to a reservation policy dispute. The society had framed rules for employee service conditions without a provision for reservation in promotions, as decided in a previous Supreme Court judgment. The High Court quashed reversion orders issued to employees who were wrongly promoted based on reservation policy, leading to the current appeal. The union argued that the High Court erred in reconsidering the issue already decided by the Supreme Court, citing precedents to support their claim.The employees benefiting from the reservation policy defended the High Court's decision, stating that relevant factors ignored by the Supreme Court were considered by the High Court. The Supreme Court analyzed submissions, previous judgments, and the impugned judgment, concluding that the High Court erred in deviating from the Supreme Court's decision, especially since the promotion policy rules remained unchanged. A review application in the previous case had been rejected, making the Supreme Court's judgment final.The Supreme Court emphasized that once orders were issued based on its judgment, the High Court could not invalidate them by considering additional factors. It reiterated that the High Court should not have questioned the legality of the reservation policy in promotions after the Supreme Court's final decision. The Supreme Court criticized the High Court's departure from the established law, warning against undermining the finality of Supreme Court decisions and violating Article 141 of the Indian Constitution.Ultimately, the Supreme Court held that the High Court's judgment was erroneous in not adhering to the Supreme Court's decision and set it aside. The appeal was allowed with no order as to costs, emphasizing the importance of lower courts following and upholding Supreme Court judgments to maintain legal consistency and certainty.