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    <title>2010 (5) TMI 805 - Supreme Court</title>
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    <description>Rules made under the proviso to Article 309 were held to operate without any special publication requirement where no mode is prescribed, so publication through the Government Orders was sufficient and separate Official Gazette publication of the retrospective clause was unnecessary. The Court also held that seniority in service is not a vested or accrued right, so a retrospective amendment altering seniority does not fail merely because it affects future promotional prospects. On the amended text of G.O.Ms. No. 51, the provision was treated as a rule of appointment, not a mere training measure, because it made eligible Forest Range Officers direct recruits to the post of Assistant Conservators of Forests.</description>
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