Sealed cover procedure applies only after charge-sheet issuance; pending inquiry alone cannot justify withholding promotion.

The sealed cover procedure may be used only after disciplinary proceedings have commenced, meaning a charge-sheet or charge-memo has been issued. A mere preliminary inquiry, CBI inquiry, or contemplated action is insufficient to withhold promotion. Where the DPC had already recommended the employee, juniors were promoted, and no charge-sheet existed at that time, later issuance of a charge-sheet could not validate the earlier denial. The contrary authority was distinguished on its facts, and later decisions were treated as consistent with this principle. The employee was therefore entitled to promotion from the date his juniors were promoted.

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Issues: Whether the respondent's promotion could be withheld under the sealed cover procedure on the basis of a pending preliminary inquiry and later approval-related scrutiny, despite no charge-sheet or disciplinary proceeding having been initiated when the DPC met and juniors were promoted.

Analysis: The controlling principle applied was that the sealed cover procedure can be invoked only after disciplinary proceedings have commenced, which occurs when a charge-sheet or charge-memo is issued. A mere preliminary investigation, CBI inquiry, or contemplation of action is insufficient. On the relevant dates, the DPC had already recommended the respondent, juniors had been promoted, and no charge-sheet had been issued. The later issuance of the charge-sheet could not justify the earlier denial of promotion. The cited later decisions were treated as consistent with this rule, while the relied-upon contrary authority was distinguished on its facts.

Conclusion: The withholding of promotion was unjustified and the respondent was entitled to promotion with effect from the date his juniors were promoted.

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