Ad hoc service and seniority: prior officiating service could not outrank direct recruits where service rules fixed placement.

Where service rules expressly governed cadre structure and seniority, earlier ad hoc or officiating service before regularisation was not counted to give seniority over direct recruits. The text rejects the argument that screening and later regularisation are equivalent to direct recruitment, because the regularised employees remained outside the cadre until regularisation and the inter se seniority of same-year recruits was determined by merit under the rules. Principles used in disputes between direct recruits and promotees were held inapplicable to a dispute between direct recruits alone. The regularised employees were therefore placed below the later direct recruits, and claims for higher seniority and consequential promotional benefits failed.

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Issues: Whether ad hoc or officiating service rendered before regularisation could be counted for seniority among direct recruits when the service rules expressly governed seniority and the regularised employees were placed below the regular recruits of the later examination year.

Analysis: The service rules created the cadre structure, prescribed the mode of direct recruitment, and indicated that inter se seniority of recruits of the same year was to be determined on merit. The regularised employees had remained outside the cadre until the date of regularisation and their earlier ad hoc service could not override the express rule-based scheme. The claim to equate screening and regularisation with regular recruitment was rejected, and the principles applied in disputes between direct recruits and promotees were held inapposite to a dispute between direct recruits alone. Where service rules clearly regulate seniority, length of prior ad hoc service cannot displace the rule-based placement of regularised employees below the regular recruits.

Conclusion: The earlier ad hoc service was not liable to be counted for seniority, the regularised employees were correctly placed below the 1970 direct recruits, and the claims for higher seniority and further promotional benefits on that basis failed.

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