Expired minor penalty cannot alone block promotion; overall service record must govern suitability assessment.

A minor penalty, once its currency has expired, cannot by itself be used to declare a State Civil Service officer unfit for promotion to the Indian Administrative Service. Suitability must be assessed through an overall relative evaluation of the officer's service record under the applicable promotion framework, including performance over the relevant years and the circumstances of any penalty. Mechanical continuation of the adverse effect of the past penalty beyond its period was not accepted, because the case had been decided on the penalty alone without the required holistic appraisal. The rejection of the representation was set aside and the matter required reconsideration by a review selection committee on the basis of the full service record.

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Issues: Whether a minor penalty imposed on the applicant could be used to declare him unfit for promotion to the Indian Administrative Service after the currency of the penalty had expired, and whether his suitability had to be assessed on the basis of his overall service record in accordance with the applicable promotion framework.

Analysis: The applicable recruitment and promotion scheme required the Selection Committee to classify eligible State Civil Service officers on an overall relative assessment of their service records as outstanding, very good, good or unfit. The decision also noted that the general administrative guidelines on promotion contemplate consideration of the full record, including the circumstances of any penalty, and that denial of promotion after the penalty period is over is not justified merely because a penalty had once been imposed. The internal guideline relied upon by the respondents was not accepted as a basis for mechanically continuing the adverse effect of the penalty beyond its currency without an overall assessment of suitability. The applicant's case was found to have been decided on the penalty alone, without the required holistic appraisal of performance for the relevant years.

Conclusion: The applicant could not be denied promotion merely on the basis of the expired minor penalty, and his case required reconsideration by a review selection committee on the basis of his overall service record. The rejection of his representation was set aside, and consequential consideration for promotion was directed.

Ratio Decidendi: After the currency of a minor penalty has expired, suitability for promotion must be determined on an overall assessment of the officer's service record and cannot be rejected solely by giving continued effect to the past penalty.

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