Administrative promotion assessment need not record reasons absent statutory mandate; judicial review is limited to arbitrariness or regulatory breach.

An expert selection committee making an administrative assessment for promotion may evaluate comparative merit on the basis of prescribed service records, including ACRs, where the governing regulation requires overall relative assessment. In the absence of a statutory requirement, it is not legally bound to record reasons for grading an officer, and non-perusal of the service register by itself does not invalidate the assessment. Judicial review remains limited and will not disturb the evaluation unless it is shown to be arbitrary or contrary to the applicable regulations.

---

---

Issues: (i) Whether the Selection Committee was bound to consider the service register apart from the Annual Confidential Reports and to record reasons while grading an officer in the promotion process; (ii) Whether the non-selection of the officer for promotion to the Indian Police Service was arbitrary or contrary to the governing regulations.

Issue (i): Whether the Selection Committee was bound to consider the service register apart from the Annual Confidential Reports and to record reasons while grading an officer in the promotion process.

Analysis: Regulation 5(4) required an overall relative assessment of the service records, and the material placed before the Committee, including the ACRs, was sufficient to judge comparative merit. The record did not support the view that non-perusal of the service register by itself vitiated the selection. The Committee's function in classifying officers was administrative, and in the absence of any statutory requirement, it was under no legal obligation to record reasons for its assessment.

Conclusion: The Selection Committee was not legally bound to record reasons, and the absence of the service register did not invalidate the assessment.

Issue (ii): Whether the non-selection of the officer for promotion to the Indian Police Service was arbitrary or contrary to the governing regulations.

Analysis: The additional affidavit and the selection record showed that the officer was assessed on the basis of the relevant five-year ACR block and was graded only as 'Very Good' because he did not secure 'Outstanding' for four of the five years considered. The Court found no unfairness or arbitrariness in that grading. It also declined to interfere with the expert evaluation made by the Commission, noting the limits of judicial review in such matters.

Conclusion: The non-selection was neither arbitrary nor contrary to the regulations.

Final Conclusion: The High Court's interference was set aside, and the Tribunal's dismissal of the application was restored, leaving the promotion decision undisturbed.

Ratio Decidendi: In the absence of a statutory requirement, an expert selection committee making an administrative assessment on the basis of prescribed service records is not required to record reasons, and its evaluation will not be disturbed in judicial review unless it is shown to be arbitrary or contrary to the governing regulations.

---