Compulsory retirement must rest on the whole service record, not a solitary adverse entry, or the order becomes invalid.

Compulsory retirement is not punitive, but it must rest on a bona fide assessment of the employee's entire service record and not on an isolated adverse entry. Judicial review remains limited, yet interference is justified where the authority acts arbitrarily, ignores vital material, or relies on irrelevant considerations. The Court found that the adverse 1987-88 report was treated as the sole basis for retirement while earlier and later confidential entries showing generally satisfactory and meritorious service were not properly considered. The fact that the employee had later been promoted also undermined reliance on that single entry. The retirement order was therefore invalid and liable to be set aside.

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Issues: Whether the order of compulsory retirement was sustainable when it was founded only on a solitary adverse entry and the relevant authority did not consider the appellant's entire service record in deciding whether retirement was in public interest.

Analysis: Compulsory retirement is not punitive and may be ordered in public interest, but the decision must be based on a bona fide evaluation of the whole service record, with due weight to later service and overall performance. Judicial review is limited, yet the Court may interfere where the order is arbitrary, mala fide, based on no evidence, or where vital material has been ignored and irrelevant material has been relied upon. Here, the adverse report for 1987-88 was treated as the sole foundation, while earlier and subsequent confidential entries showing generally satisfactory service, good conduct, and meritorious performance were not objectively considered. The record also showed that the appellant had been promoted after the adverse remarks, which reinforced the conclusion that the isolated entry could not, by itself, justify compulsory retirement.

Conclusion: The order of compulsory retirement was invalid and liable to be set aside because it was based on an arbitrary and incomplete assessment of the service record, rather than a proper public-interest evaluation.

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