Year of allotment seniority upheld, but discriminatory validation against similarly placed direct recruits was struck down as unequal.

The year of allotment remained the governing principle for inter se seniority in the integrated service because the long-settled arrangement had been consistently followed and had already been judicially approved, so the challenge to that seniority framework failed. Section 3(2)(a) of the Orissa Administrative Service Class II (Appointment of Officers Validation) Act, 1986 was unconstitutional to the extent it gave preferential treatment to 1970 and 1971 direct recruits over similarly situated 1972 direct recruits, as the classification lacked a rational basis and offended equality. The settled seniority scheme was maintained, while the discriminatory part of the validating provision was struck down.

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Issues: (i) Whether the long-accepted principle of year of allotment governing inter se seniority in the integrated service could be unsettled. (ii) Whether Section 3(2)(a) of the Orissa Administrative Service Class II (Appointment of Officers Validation) Act, 1986 was valid insofar as it treated the 1972 direct recruits differently.

Issue (i): Whether the long-accepted principle of year of allotment governing inter se seniority in the integrated service could be unsettled.

Analysis: The integration of the two earlier cadres had been acted upon for years, and the seniority structure had been worked out on the basis of the year of allotment. A prior Full Bench decision had upheld that approach after considering the service history and the settled practice. The Court treated that earlier decision as binding and declined to disturb a position that had been consistently followed and had acquired settled character in the service jurisprudence of the State.

Conclusion: The principle of year of allotment was upheld and the challenge to the settled seniority framework failed.

Issue (ii): Whether Section 3(2)(a) of the Orissa Administrative Service Class II (Appointment of Officers Validation) Act, 1986 was valid insofar as it treated the 1972 direct recruits differently.

Analysis: Once the year of allotment principle was accepted, the Court found no rational basis for protecting the seniority of the 1970 and 1971 direct recruits while denying the same treatment to the 1972 direct recruits. The two sets of direct recruits were similarly situated, and the selective validation created an artificial classification without a reasonable nexus. That differential treatment was held to offend the equality guarantee.

Conclusion: Section 3(2)(a) was declared unconstitutional to the extent it placed the deemed promotees of 1972 above the 1972 direct recruits.

Final Conclusion: The settled seniority principle based on year of allotment was maintained, the broad challenge to the service integration scheme failed, and only the discriminatory part of the validating provision was struck down; one connected writ petition was left without final adjudication on merits.

Ratio Decidendi: A long-standing and judicially approved seniority arrangement based on year of allotment should not be unsettled absent a rational legal basis, and any validating classification that treats similarly placed direct recruits differently without reasonable justification is violative of Article 14.

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