Separate promotion quotas require qualifying service within the relevant category, and prior service cannot be counted across streams.

Promotion rules with separate fixed quotas for degree holders and diploma holders required qualifying service to be rendered within the relevant category. Diploma-holder Project Engineers (Junior) who later acquired AMIE could not count pre-AMIE service toward eligibility under the degree-holder quota, because the scheme treated the two streams as distinct promotional compartments and did not permit inter-changeability absent express rule-based authorization. Separate seniority lists were not required; common entry-level seniority remained governed by the recruitment process, while quota-specific eligibility could be assessed separately for promotion purposes.

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Issues: (i) Whether diploma-holder Project Engineers (Junior), after acquiring AMIE, could count their pre-AMIE service for eligibility against the 20% quota reserved for degree-holder Project Engineers (Junior) for promotion to Project Engineer (Senior). (ii) Whether separate seniority lists for degree holders and diploma holders were required to be maintained for promotion purposes.

Issue (i): Whether diploma-holder Project Engineers (Junior), after acquiring AMIE, could count their pre-AMIE service for eligibility against the 20% quota reserved for degree-holder Project Engineers (Junior) for promotion to Project Engineer (Senior).

Analysis: The promotional scheme created distinct and fixed quotas for degree holders and diploma holders, each with its own eligibility requirement of service coupled with qualification. The expression requiring three years' service for degree holders and seven years' service for diploma holders was construed as referring to service rendered within the relevant qualifying class, so that the quota for degree holders could not be entered by treating earlier diploma service as equivalent to degree-holder service. The use of the word "total" did not alter this position, as it was understood to refer to the aggregate of regular and other service in the relevant capacity, not to permit inter-changeability between the two channels. The scheme was treated as creating separate compartments for the two promotional streams, and the authorities' contrary view was held inconsistent with the regulatory framework.

Conclusion: The diploma-holder Project Engineers (Junior) who acquired AMIE were not entitled to count their pre-AMIE service for eligibility against the degree-holder quota; three years' qualifying service had to be rendered after acquiring the degree-equivalent qualification.

Issue (ii): Whether separate seniority lists for degree holders and diploma holders were required to be maintained for promotion purposes.

Analysis: Seniority at the entry level was governed by the common recruitment process and the initial merit-based selection, and the regulations did not authorise bifurcation of the cadre into two separate seniority streams merely because different promotional quotas existed for later advancement. Separate eligibility lists could be prepared for determining whether candidates satisfied the respective quota conditions, but that was distinct from seniority. The regulations were read as not permitting alteration of the common seniority position solely on the basis of later acquisition of AMIE by diploma holders.

Conclusion: Separate seniority lists were not required to be maintained for degree holders and diploma holders.

Final Conclusion: The challenge succeeded only on the promotional eligibility issue, while the ruling rejecting separate seniority lists was left undisturbed; the matter stood disposed of by applying the clarified interpretation of the recruitment and promotion scheme.

Ratio Decidendi: Where a promotion rule prescribes separate fixed quotas with distinct qualifying service for two categories, the required service must be rendered within the category for which promotion is claimed, and prior service in another category cannot be counted unless the rules expressly permit such equivalence.

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