Mala fides and bias in promotion examination require specific proof; vague allegations cannot invalidate the selection process.

The conduct of a promotion examination in a Regional Rural Bank was governed by the applicable rules, which vested the examination with the Banking Institute and not the Chairman, and the written test and merit list were prepared by the examining body. Allegations that the selection was tainted by mala fides, bias, and unfairness failed because they rested on vague pleadings, relationship-based suspicion, and unproved irregularities in custody or transmission of papers. The governing principle is that mala fides and bias must be supported by specific particulars and cogent proof, not conjecture. On the material available, no manipulation of the examination or merit list was established.

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Issues: Whether the promotion examination and resulting selection in the Regional Rural Bank were liable to be quashed on the ground of mala fides, bias, and unfairness attributed to the then Chairman.

Analysis: The governing rules vested the conduct of the examination in the Banking Institute, Mumbai, under the framework of the Regional Rural Banks Act, 1976 and the Rules governing appointment and promotion. The material on record showed that the written test was conducted by the examining body, the merit list was prepared by it, and the Chairman did not head the selection committee. The allegation of bias rested mainly on the Chairman's relationship with certain candidates and on supposed irregularities in custody and transmission of papers, but the pleadings were vague and unsupported by cogent evidence. The principles governing mala fides require specific particulars and strong proof, and a mere suspicion or general allegation does not establish a real danger of bias. The report relied upon by the appellants did not demonstrate that the examination itself was vitiated or that the merit list was manipulated.

Conclusion: The challenge to the examination and selection failed, as no proved mala fide, arbitrariness, or legally sustainable bias was shown.

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