Supreme Court Judgment on IAS Officer’s Promotion Denial: Key Legal Analysis

The Supreme Court of India recently delivered a significant judgment in the case of Raju Narayana Swamy vs. State of Kerala & Ors., which revolved around the denial of promotion to an IAS officer to the grade of Chief Secretary. The judgment, authored by Justice Joymalya Bagchi and Justice Pamidighantam Sri Narasimha, provides a detailed analysis of the principles governing promotions in the Indian Administrative Service (IAS) and the role of Annual Confidential Reports (ACRs) in such decisions.

The appellant, Raju Narayana Swamy, is a 1991 batch IAS officer of the Kerala cadre with a brilliant academic record. He was promoted to the grade of Principal Secretary in 2016 and subsequently sought promotion to the Chief Secretary grade. The selection process for this promotion is governed by Clause VI of the ‘Principles regarding Promotion of Members of IAS’ under the IAS (Pay) Rules, 2016. The Screening Committee, responsible for assessing eligibility, found the appellant unsuitable for promotion, citing incomplete ACRs and unsatisfactory performance.

The appellant challenged this decision, arguing that the Review Committee considered extraneous materials and pre-2016 adverse entries in his ACRs, which should have been disregarded post his promotion. The respondents, however, contended that the Committee was justified in examining the entire service record, including instances of unauthorized absence and lack of interpersonal skills.

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The Supreme Court, in its judgment, emphasized that while prior adverse entries lose their sting post-promotion, they can still be considered as ‘weak material’ unless they pertain to dishonesty or lack of integrity. The Court noted that the appellant’s conduct post-2016, including a year-long unauthorized absence, validated the Committee’s decision to deny promotion. The judgment also highlighted the importance of discipline and collegiality in higher administrative roles.

Key arguments from the judgment include:

Justice Joymalya Bagchi observed: “Individual excellence may sometimes lead to superiority complex and hinder commitment to discipline, decorum and collegiality. Keeping in mind the essential requisite of collective leadership in highest echelons of civil service, the Committee was justified in giving due weightage to lack of adherence to discipline and collegiality.”

The Court further noted: “The Review Committee had examined the entire service record of appellant and noted that in 2019-20 appellant had absented himself for about a year without justifiable cause. A show cause notice was also issued in this regard. Subsequently the said period has been treated as ‘non-duty’ i.e. absence without leave. This conduct was taken into consideration to deny promotion to appellant to the highest echelon of civil service.”

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The judgment also referenced precedents such as Badrinath vs. Government of Tamil Nadu & Ors., where the Court summarized principles regarding the consideration of adverse remarks in promotions. The Court held that the Screening Committee’s decision was neither mala fide nor unreasonable, and thus, no interference was warranted.

In conclusion, the Supreme Court dismissed the appeal, upholding the decisions of the Screening and Review Committees. The judgment underscores the rigorous standards expected for promotions to top administrative positions and the judiciary’s reluctance to interfere in such matters unless there is clear evidence of mala fide or procedural irregularity.

Petitioner Name: Raju Narayana Swamy.
Respondent Name: State of Kerala & Ors..
Judgment By: Justice Joymalya Bagchi, Justice Pamidighantam Sri Narasimha.
Place Of Incident: Kerala.
Judgment Date: 23-04-2025.
Result: dismissed.

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