Cadre integration and promotion equality: source-based distinctions after absorption into one cadre were held constitutionally invalid.

Once direct recruits and promotees are absorbed into a common cadre, they cannot ordinarily be treated differently for future promotion merely because they came from different sources. Service classification must rest on an intelligible differentia with a rational nexus to the object sought to be achieved; a source-based distinction is valid only where it reflects a relevant merit-based criterion, such as higher qualifications or administrative efficiency. Note 6 to Rule 3 of the Andhra Pradesh Educational Service Rules was invalid because it differentiated only between direct recruits and promotees after integration into one cadre. The roster justification was not a constitutionally permissible basis, and the note was held unconstitutional under Articles 14 and 16.

---

---

Issues: Whether officers drawn from different sources and integrated into one cadre could still be classified for further promotion on the basis of their source of recruitment, and whether the roster in Note 6 to Rule 3 of the Andhra Pradesh Educational Service Rules was constitutionally valid.

Analysis: The governing principle is that once direct recruits and promotees are absorbed into a common cadre or class, they cannot ordinarily be subjected to differential treatment in the matter of future promotion merely because they came from different sources. A classification in service matters must rest on an intelligible differentia having a rational nexus with the object sought to be achieved. The earlier decision in Roshan Lal Tandon was treated as stating the general rule, while Triloki Nath Khosa was understood as permitting classification on a permissible basis such as higher educational qualifications where the object was administrative efficiency. Note 6, however, did not classify on the basis of qualification or any other relevant merit-based criterion, but only on whether an officer was a direct recruit or a promotee after integration into one cadre. The suggested justification of correcting an alleged imbalance in roster placement did not supply a constitutionally valid basis for such differentiation.

Conclusion: Note 6 to Rule 3 was unconstitutional and violative of Articles 14 and 16 of the Constitution of India; the appeals therefore failed.

---