Judicial review cannot replace a statutory selection committee's merit assessment in promotion matters absent mala fides or rule violation.

A statutory Selection Committee's comparative assessment of eligible officers for promotion to the Indian Forest Service under the 1966 Regulations, based on service records and annual confidential reports, is not ordinarily open to judicial interference when there is no allegation of mala fides or breach of the governing rules. Courts should confine review to legality of the process and not substitute their own view of merit for that of the expert body. On that basis, the Tribunal and High Court's interference and direction to convene a review promotion committee were held unsustainable, and the selection made by the Committee was restored.

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Issues: Whether the Selection Committee's grading of eligible officers for promotion to the Indian Forest Service under the I.F.S. (Appointment by Promotion) Regulations, 1966 could be interfered with on judicial review; and whether the direction to convene a review promotion committee was justified.

Analysis: The Regulations required the Selection Committee to assess eligible officers on the basis of their service records and annual confidential reports and to classify them as outstanding, very good, good, or unfit for preparing the select list. The impugned selection was made by the committee constituted under the Regulations, and there was no allegation of mala fides. In such matters, evaluation by an expert body is not ordinarily to be displaced by courts merely because a different view of comparative merit is possible. The Tribunal and the High Court, instead of confining themselves to the legality of the process, entered into the merits of the assessment and substituted their own view for that of the Selection Committee.

Conclusion: The interference with the selection process was unwarranted, and the direction to hold a review committee was unsustainable.

Final Conclusion: The selection made by the statutory Selection Committee was restored and the orders of the Tribunal and the High Court were set aside.

Ratio Decidendi: Courts should not interfere with a statutory expert committee's comparative merit assessment in promotion matters in the absence of mala fides or violation of the governing regulations.

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