The Chhattisgarh High Court has dismissed a petition challenging the merit-based promotion of senior forest officer VS Rao to the post of Principal Chief Conservator of Forests (Head of Forest Force) in the Apex Scale, emphasizing that competence and performance outweigh seniority in selection processes for top bureaucratic roles.

The ruling, delivered by a division bench comprising Justice Rajani Dubey and Justice Narendra Kumar Vyas, upheld the 2023 promotion of Rao, a 1990-batch Indian Forest Service (IFS) officer, over 1988-batch officer Sudhir Kumar Agrawal. Agrawal had contested the promotion, alleging violations of seniority norms and procedural guidelines.

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Agrawal, the petitioner, argued that Rao’s elevation to the Apex Scale, a position equivalent to Level 17 in the pay matrix was unlawful, citing Rao’s junior batch status and an alleged lack of the mandatory one-year service in Level 16. He further contended that the 2009 Ministry of Environment, Forest and Climate Change (MoEFCC) guidelines and the Indian Forest Service (Pay) Rules, 2016, were breached, as promotions to the Apex Scale require “outstanding merit, integrity, and suitability.”

The State Government and Union of India countered that the appointment was strictly merit-based. They highlighted that a Special Selection Committee (SSC) evaluated candidates using Annual Performance Assessment Reports (APARs), where Rao scored 49.62 out of 50 compared to Agrawal’s 48. The SSC also factored in Rao’s exoneration in a decade-old departmental inquiry, dismissing Agrawal’s allegations of pending financial irregularities.

The bench clarified that the Apex Scale is a selection post, not a promotion post, governed by MoEFCC guidelines and Pay Rules emphasizing merit. “Seniority is irrelevant when the criteria demand selecting the most competent candidate,” the court observed, citing a 2022 Supreme Court precedent (State of Madhya Pradesh vs RD Sharma). It further noted that the one-year service rule cited by Agrawal applied only to promotions, not selections.

Justice Vyas, authoring the order, stated, “The Tribunal rightly concluded that the SSC followed due process. Interference under Article 227 is unwarranted unless there is a patent illegality, which is absent here.”

The judgment reinforces the growing judicial emphasis on performance-based appointments in civil services. Legal experts suggest it may set a precedent for similar disputes nationwide, particularly in roles requiring specialized expertise.

“This verdict reaffirms that seniority alone cannot supersede merit in critical leadership positions,” said Chhattisgarh based advocate Anand Narayan Gupta. Meanwhile, State Advocate General Prafull N. Bharat hailed the decision as “a win for transparency in bureaucratic appointments.”

With the High Court’s dismissal, Rao’s promotion stands validated, closing a contentious chapter in Chhattisgarh’s forest administration. The ruling underscores the judiciary’s alignment with administrative reforms prioritizing efficiency and accountability in governance.