Compulsory retirement based on entire service record survives review absent mala fides, arbitrariness, perversity, or no relevant material.

Compulsory retirement under Rule 56(j) of the Fundamental Rules is an independent administrative action taken on the competent authority's subjective satisfaction in public interest. It is not punitive, carries no stigma, and does not attract natural justice in the same manner as disciplinary action. Judicial review is limited to examining mala fides, arbitrariness, perversity, or non-application of mind, and the entire service record may be considered, including adverse material and conduct. On the facts, the Review Committee had examined the complete record, and the challenge based on legal malice, procedural illegality, delay, arbitrariness, or breach of assurance failed.

---

---

Issues: Whether the order of compulsory retirement under Rule 56(j) of the Fundamental Rules, and the rejection of the representation, were liable to be quashed on the grounds of mala fides, arbitrariness, delay, or breach of assurance.

Analysis: Compulsory retirement under Rule 56(j) is an independent administrative decision based on the subjective satisfaction of the competent authority in public interest. The Court reiterated that such retirement is not a punishment, carries no stigma, and does not attract the principles of natural justice. Judicial review is confined to examining whether the decision is vitiated by mala fides, arbitrariness, perversity, or non-application of mind. The entire service record may be considered, including adverse material and service-related conduct, and promotion or success in earlier litigations does not bar an assessment that continuation in service is no longer desirable. The Court found that the Review Committee had considered the petitioner's complete record and that the decision was not shown to be infected by legal malice, procedural illegality, or any enforceable breach of assurance.

Conclusion: The challenge to the compulsory retirement order and the connected rejection of representation failed; the action was upheld.

Ratio Decidendi: An order of compulsory retirement based on consideration of the entire service record and formed in bona fide public interest is immune from interference unless it is shown to be mala fide, arbitrary, perverse, or based on no relevant material.

---