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    <description>A special police promotion regime under the Police Act, 1861 and the Government Order issued under it is not displaced by later general rules framed under Article 309 unless there is express repeal or unavoidable inconsistency. Non-publication of the Government Order in the Official Gazette was treated as non-fatal where it functioned as an executive instruction long acted upon in the department. Annual selection irregularities, including clubbing select lists instead of preparing separate year-wise lists, were treated as curable procedural defects and not, by themselves, a basis to invalidate the promotion process absent substantive illegality.</description>
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