Forest cadre promotion requires genuine forestry linkage; pay parity alone does not make a non-forest post equivalent.

A post qualifies as a feeder post for promotion into a forest cadre only if its duties, qualifications and statutory recognition show a genuine connection with forestry; mere parity in pay or earlier inclusion in a schedule is insufficient. On that basis, the post of Assistant Mill Manager was treated as a technical milling post, not equivalent to Assistant Conservator of Forests and not eligible for consideration for promotion to Deputy Conservator of Forests. The document also states that review jurisdiction is limited to correcting an error apparent on the face of the record and cannot be used to reappreciate the case on merits; the Tribunal exceeded that limit, so its review order could not stand.

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Issues: (i) Whether the post of Assistant Mill Manager was equivalent to the post of Assistant Conservator of Forests and was a service connected with forestry so as to entitle the appellant to consideration for promotion to the cadre post of Deputy Conservator of Forests. (ii) Whether the Tribunal was justified in allowing the review application and reversing its earlier order without demonstrating any error apparent on the face of the record.

Issue (i): Whether the post of Assistant Mill Manager was equivalent to the post of Assistant Conservator of Forests and was a service connected with forestry so as to entitle the appellant to consideration for promotion to the cadre post of Deputy Conservator of Forests.

Analysis: The relevant recruitment and promotion scheme under the forest service rules required that the feeder post be part of the State Forest Service or otherwise a Central Civil post connected with forestry and approved for that purpose. The post of Assistant Mill Manager was held to be a technical post concerned with milling and timber processing, not with forest administration, forest policy, or duties directly connected with forestry. The qualifications and promotional channels of the two posts were materially different, and parity in pay alone did not establish equivalence of cadre status or functional identity. The later service rules also confined the promotional channel for the cadre post to the forest-side officers, particularly Assistant Conservator of Forests.

Conclusion: The post of Assistant Mill Manager was neither equivalent to the post of Assistant Conservator of Forests nor a post connected with forestry, and the appellant was not entitled to consideration for promotion to the post of Deputy Conservator of Forests.

Issue (ii): Whether the Tribunal was justified in allowing the review application and reversing its earlier order without demonstrating any error apparent on the face of the record.

Analysis: Review jurisdiction is confined to correcting a manifest error and does not permit a rehearing on merits or the substitution of an entirely fresh decision. The Tribunal, instead of identifying any apparent error in its first order, reappreciated the entire controversy and effectively sat in appeal over its own judgment. Such an exercise was beyond the permissible scope of review.

Conclusion: The Tribunal exceeded its review jurisdiction and its review order could not be sustained.

Final Conclusion: The common judgment of the High Court setting aside the Tribunal's review order was upheld, and the appeals failed.

Ratio Decidendi: A post can be treated as a feeder post for promotion to a forest cadre only if its duties, qualifications, and statutory recognition show that it is genuinely connected with forestry; parity in pay or inclusion in an earlier schedule is insufficient, and review cannot be used to re-decide the case on merits absent an error apparent on the face of the record.

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