Sealed cover procedure

The sealed cover procedure is the rule under which a departmental promotion committee assesses a central government servant facing a disciplinary or criminal case in the ordinary way, places its recommendation in a sealed cover instead of acting on it, and leaves the promotion to be decided when the case ends. It is set out in Department of Personnel and Training Office Memorandum No. 22011/4/91-Estt.(A) dated 14 September 1992, which runs to nine paragraphs and has not been amended since.

The device answers a problem that has no clean solution. A servant under a cloud cannot be shut out of the field of choice, because a charge is not a finding and the charge sheet may fail. Nor can the servant be promoted while the cloud remains, because the department would then be rewarding a person it is simultaneously prosecuting. The sealed cover preserves the assessment made on the material actually available on the day, and defers only the consequence.

The instruction was issued in supersession of six earlier orders spanning 1960 to 1991, after the Supreme Court decided Union of India v. K. V. Jankiraman, (1991) 4 SCC 109, on 27 August 1991. Jankiraman settled two questions that the earlier instructions had left open: when proceedings are pending for this purpose, and whether a servant later exonerated is entitled to money as well as to a restored date. The 1992 order carries both answers, and the second of them, the reasoned discretion over arrears, is what separates a restored date of promotion from a payment.

Three consequences follow for a reader tracking a real case. The procedure attaches to three named situations and to nothing else. The cover cannot be opened on anything short of complete exoneration, and a penalty of any grade, including a censure, kills the findings inside it outright. And the only discipline on how long a cover may be held is a six monthly review and the two year ad hoc promotion route, neither of which is an outer limit.

This article sets out where the procedure comes from, the three categories it covers and the threshold at which each attaches, what the committee writes and seals, the deemed sealed cover for an officer who comes under a cloud after the committee has met, the six monthly review, ad hoc promotion after two years, what opening the cover produces on complete exoneration, what a penalty or a conviction produces instead, the position where a trial court acquittal is under appeal, exoneration after retirement and its pension effect, confirmation, what the procedure does not reach, how it differs from a refusal of vigilance clearance, how the Indian Administrative Service version diverges, and the citation trap that the department’s own consolidation has created.

Where the procedure comes from

The 1992 Office Memorandum is a codification of Jankiraman, not an independent policy. Its opening paragraph refers to the earlier instruction of 12 January 1988, records the review undertaken after the judgment of 27 August 1991, and supersedes six orders printed in the margin: No. 39/3/59-Estt.(A) dated 31 August 1960, No. 7/28/63-Estt.(A) dated 22 December 1964, No. 22011/3/77-Estt.(A) dated 14 July 1977, No. 22011/1/79-Estt.(A) dated 31 January 1982, No. 22011/2/86-Estt.(A) dated 12 January 1988, and No. 22011/1/91-Estt.(A) dated 31 July 1991. Six orders issued over 31 years were replaced by one.

What Jankiraman decided has two limbs. On commencement, the Supreme Court agreed with the Full Bench of the Central Administrative Tribunal that proceedings are initiated only when a charge memo in a departmental case or a charge sheet in a criminal prosecution is issued, and that the pendency of a preliminary investigation before that stage does not let the authorities adopt the sealed cover procedure. On money, the Court rejected the no work no pay principle as inapplicable to a servant who is willing to work but is kept away from work by the authorities through no fault of his own, then struck out the sentence in the departmental memorandum that had made arrears mandatory and replaced it with a discretion to be exercised on the facts, with reasons recorded for any denial.

The order is signed by a Director in the Ministry of Personnel, Public Grievances and Pensions and was copied to the Central Vigilance Commission, the Central Bureau of Investigation, the Union Public Service Commission, the Comptroller and Auditor General, and the Chief Secretaries of all States and Union Territories. Paragraph 8 records that it issued in consultation with the Comptroller and Auditor General so far as the Indian Audit and Accounts Department is concerned, which is the standard clause wherever an establishment instruction reaches that department.

The three categories that attract a sealed cover

Paragraph 2 of the 1992 Office Memorandum names three categories of government servant whose cases must be brought to the committee’s notice: those under suspension; those in respect of whom a charge sheet has been issued and disciplinary proceedings are pending; and those in respect of whom prosecution for a criminal charge is pending. The list is exhaustive. A servant outside all three is considered and, if found fit, promoted with everyone else.

Pendency of a criminal prosecution takes its meaning from the pension rules, not from the criminal procedure. The 1992 order did not define the term, and paragraph 8 of Office Memorandum No. 22034/4/2012-Estt.(D) dated 2 November 2012 supplied the answer by borrowing the definition of pendency of judicial proceedings now carried in Explanation 1(b)(i) under Rule 8 of the CCS (Pension) Rules, 2021: criminal proceedings are deemed instituted on the date on which the complaint, or the report of a police officer of which the magistrate takes cognizance, is made.

The charge sheet threshold

The date on which a case becomes a sealed cover case is the date the charge memo issues, not the date the department first suspected something. Two later decisions fix the boundary in opposite directions.

In Delhi Development Authority v. H. C. Khurana, (1993) 3 SCC 196, the Supreme Court held that a charge sheet is issued once the decision to proceed is taken and the sheet is framed and despatched, and that service on the employee is not required. Delay in the post does not save a promotion. In Union of India v. Anil Kumar Sarkar, (2013) 4 SCC 161, the employee was not under suspension, had been served no charge sheet and faced no prosecution on 21 April 2003, the day his batch mates were promoted; the charge sheet came on 13 August 2003. The Court held that where none of the three conditions exists on the relevant date, the committee’s recommendation has to be honoured.

Union of India v. Doly Loyi, 2024 INSC 729, decided on 24 September 2024, closed the remaining gap. An Additional Commissioner of Income Tax had his recommendation sealed at a committee that met on 22 February 2007, on the footing that a criminal prosecution was pending. Sanction to prosecute had been granted on 2 June 2006, but the Central Bureau of Investigation filed its charge sheet only on 25 October 2008. The Court held that neither the pendency of the investigation nor the grant of sanction reaches the threshold. A sanction blocks nothing at a promotion committee.

What the committee writes and what happens to the post

Paragraph 2.1 of the 1992 Office Memorandum sets out the mechanics, and the order of operations matters. The committee assesses the servant along with every other eligible candidate without taking the pending case into consideration, which means the case may not be used as a reason to grade the servant down. The assessment, including a finding of unfitness and the grading awarded, then goes into a cover superscribed with the grade or post, the servant’s name, and the direction that it is not to be opened until the disciplinary case or criminal prosecution is terminated. The committee’s own proceedings record nothing beyond a note that the findings are in the attached sealed cover.

The post does not stay vacant. The authority competent to fill it is separately advised to fill it only in an officiating capacity, which is why a sealed cover case so often produces a long officiating appointment for somebody further down the panel. Paragraph 2.2 directs every subsequent committee to follow the same procedure until the case concludes, so a case running through four annual committees generates four covers.

The deemed sealed cover

Paragraph 7 of the 1992 Office Memorandum covers the officer who is already through the committee. Where the committee has recommended the officer for promotion but one of the three circumstances arises after the recommendations are received and before the officer is actually promoted, the case is treated as if the recommendation had been placed in a sealed cover, and the officer is not to be promoted until completely exonerated. A charge sheet arriving in the window between the committee’s meeting and the promotion order therefore stops the promotion as surely as one arriving before it.

The paragraph sits outside the three category list, which is why an establishment section working from paragraph 2 alone can miss it. It also runs in one further direction: where year wise panels are drawn up for past vacancy years, the procedure is observed if proceedings are in progress on the date the committee meets, even though no proceedings existed in the year to which the vacancy related.

One limit on paragraph 7 was added later. Office Memorandum No. 22011/2/2002-Estt.(A) dated 24 February 2003, issued after the Supreme Court decided Delhi Jal Board v. Mohinder Singh, clarifies that paragraph 7 does not apply where, by the time the seal was opened to give effect to exoneration in the first inquiry, another departmental inquiry had been started. A second proceeding begun after the junior was promoted on the original committee’s recommendation therefore does not take away the benefit of the first assessment, and the servant gets it with effect from the date the immediate junior was promoted. Paragraph 4 of the same order deals with the sequence in reverse: where the later proceeding ends in a penalty before the first one ends in exoneration, and the servant is then promoted retrospectively on that exoneration, the penalty may be modified so that it takes effect with reference to the promoted post, and the promotion order should say so.

That order carries a misprint worth knowing about before it is quoted. Its subject line reports the judgment as JT 2002 (10) SC 158 and its paragraph 2 reports the same judgment as JT 2000 (10) SC 158.

The six monthly review

Paragraph 4 of the 1992 Office Memorandum obliges the appointing authority to review every sealed cover case comprehensively on the expiry of six months from the date of convening the first committee that sealed the findings, and every six months after that. The review covers the progress made in the disciplinary proceedings or the criminal prosecution and the further measures to be taken to expedite their completion.

The review is a reporting duty, not a decision point. Nothing in paragraph 4 lets the reviewing authority open the cover, and the central civil services version differs from the Indian Administrative Service version in exactly that respect. Its practical value is documentary: a servant challenging a stalled case before the Central Administrative Tribunal can ask what the six monthly reviews recorded, and an authority that held none has conceded the point on delay before the argument starts.

Ad hoc promotion after two years

Paragraph 5 of the 1992 Office Memorandum is the relief for a case that drags, and it opens two years after the meeting of the first committee, provided the officer is not under suspension. The suspension bar is express and admits no exception, whatever the elapsed time.

The appointing authority first considers the desirability of an ad hoc promotion against five stated aspects: whether the promotion would be against the public interest; whether the charges are grave enough to warrant continued denial of promotion; whether the case is likely to come to a conclusion in the near future; whether the delay in finalising the proceedings, departmental or in a court of law, is not directly or indirectly attributable to the officer; and whether there is a likelihood of misuse of the official position the officer would occupy, which might affect the conduct of the case. Where the proceedings arose out of investigations by the Central Bureau of Investigation, that agency must be consulted and its views taken into account.

Clearing that gate is not the promotion. Under paragraph 5.1 the case then goes to the next committee held in the normal course after the two year period, which decides suitability for ad hoc promotion on the totality of the service record, again without taking the pending case into account. Paragraph 5.2 requires the order to state that the promotion is purely ad hoc and confers no right to regular promotion, that it is until further orders, and that Government reserves the right to cancel it and revert the officer at any time.

The outcome of the case then determines what the ad hoc promotion becomes:

The regime is separate from the ad hoc promotion made where no committee can be convened, which is capped at one year and is screened by a selection committee in lieu of a departmental promotion committee. Only one of the two runs from a sealed cover, and only that one carries the two year gate and the suspension bar.

Opening the cover on complete exoneration

Paragraph 3 of the 1992 Office Memorandum fixes the due date of promotion by reference to two things: the position assigned to the servant in the sealed findings, and the actual date of promotion of the person ranked immediately junior by the same committee. The servant may then be promoted notionally from that date, if necessary by reverting the junior most officiating person holding the post.

The trigger is complete exoneration, and Jankiraman gave the phrase a hard edge: the employee must not be found blameworthy in the least and must not be visited with the penalty even of censure. An exoneration that stops short of that, or a proceeding closed with an admonition recorded on the file, does not open the cover.

Arrears are the separate question, and the one the 1992 order was written to settle. Whether the servant is entitled to arrears of pay for the period of notional promotion preceding the actual promotion, and if so to what extent, is decided by the appointing authority taking into account all the facts and circumstances of the proceeding. An authority denying arrears in whole or in part must record its reasons. The order gives examples of a justified denial: proceedings delayed at the servant’s own instance, a clearance or an acquittal given with the benefit of doubt, and evidence that was unavailable because of acts attributable to the servant.

A review committee cannot be used to reopen the question later on facts that arose afterwards. Office Memorandum No. 22011/2/99-Estt.(A) dated 21 November 2002 settles that the sealed cover procedure cannot be resorted to at a review departmental promotion committee where no departmental proceedings or criminal prosecution were pending against the servant, and the servant was not under suspension, at the time of the meeting of the original committee or before the promotion of the junior on that committee’s recommendation. The circumstances that count are the circumstances as they stood then.

The split between the date and the money matters. Notional promotion from the junior’s date carries the restored place in the seniority list, counts towards the minimum qualifying service for the next promotion, and refixes pay under the ordinary rules. Fundamental Rule 17(1) provides that pay and allowances accrue from the date the servant assumes charge, which is why the restored date and the money do not travel together automatically, and why the appointing authority’s recorded reasons are the whole of the servant’s case on appeal.

Where a penalty is imposed or a conviction follows

Paragraph 3.1 of the 1992 Office Memorandum provides that where any penalty is imposed as a result of the disciplinary proceedings, or the servant is found guilty in the criminal prosecution, the findings of the sealed cover shall not be acted upon, and the case for promotion may be considered by the next committee in the normal course having regard to the penalty imposed.

Two features of that sentence do the work. The bar is triggered by any penalty, so a censure under clause (i) of Rule 11 of the CCS (CCA) Rules, 1965 kills the sealed findings as effectively as a reduction in rank under clause (vi); the distinction between major and minor penalty proceedings does not carry over into this paragraph. And the earlier assessment is extinguished rather than deferred, which is why Jankiraman rejected the argument that a later committee should reconsider the case as it stood on the original date.

Paragraph 3.2 adds a clarification with a consequence that runs past this instruction. Where proceedings have been held under the disciplinary rules, a warning should not be issued as their result, and if the proceedings show that some blame attaches, at least the penalty of censure should be imposed. A file closed with a warning after a full inquiry is therefore irregular on the face of the instruction, and the irregularity works both ways: it denies the servant the appeal that a censure would carry, while leaving an adverse entry the APAR machinery was never meant to hold.

Acquittal by the trial court with an appeal pending

Office Memorandum No. 11012/6/2016-Estt.A-III dated 19 January 2017 is the most recent central instruction on the subject, and it resolves the case where the trial court has acquitted the servant but an appeal is contemplated or filed. It was framed in consultation with the Department of Legal Affairs and in the light of judgments including Bank of India v. Degala Suryanarayana, (1999) 5 SCC 762.

The clarification has three limbs. Where the recommendation was sealed solely on account of the pendency of the criminal case, the cover may be opened on acquittal, provided the acquittal has not been stayed by a superior court. The promotion order must record that the promotion is provisional and subject to the outcome of any appeal against the acquittal. And if the servant stands convicted on appeal, the provisional promotion is deemed non est and the servant stands reverted; where the sentence is imprisonment exceeding 48 hours, the servant is deemed to be under suspension under Rule 10(2)(b) of the CCS (CCA) Rules, 1965 from the date of conviction, and action follows under Rule 19(i) of those rules, which is the provision for a penalty imposed on the ground of conduct that has led to a conviction.

The limitation in the first limb is easy to lose. The relief is available where the criminal case was the sole reason for the cover. Where a departmental proceeding was running alongside, the acquittal does not open the cover and paragraph 3 of the 1992 order still requires complete exoneration in that proceeding.

The 2017 clarification does not disturb paragraph 5.4 of the 1992 order, because the two govern different objects. Paragraph 5.4 ends an ad hoc promotion already granted where the acquittal is on technical grounds and the Government proposes to appeal. The 2017 order decides whether a cover that is still closed may be opened at all, and it allows that on an unstayed acquittal even where an appeal is contemplated, against a provisional promotion order.

Exoneration after retirement

Office Memorandum No. 22011/3/2013-Estt.(D) dated 25 January 2016 allows notional promotion to a government servant exonerated after retirement, and the pension is refixed on the notional pay. Its paragraph 3 confines the instruction to two situations that must both hold: the promotion order for the relevant committee had issued and the empanelled officers had assumed charge before the date of superannuation, and the retired servant would have been in service and would have assumed charge had the proceedings not been initiated.

Where both hold, paragraph 4 sends the question of notional promotion and arrears of pay for the period of notional promotion up to the date of retirement back to the appointing authority, to be decided under paragraph 3 of the 1992 order. The reasoned discretion over arrears therefore follows the servant into retirement unchanged. Paragraph 5 adds the pension limb: a retired employee considered for notional promotion from the date of promotion of the next junior on opening of the cover is entitled to fixation of pension on the basis of the notional pay. That feeds directly into the emoluments used for pension calculation, and the order records that it was issued in consultation with the Department of Expenditure, the Department of Pension and Pensioners’ Welfare, and the Department of Legal Affairs.

The order operates from its date of issue, and cases settled under the earlier provisions are not to be reopened, which places a hard boundary at 25 January 2016 for any representation made now about a retirement that preceded it.

Confirmation and the reserved vacancy

Paragraph 6 of the 1992 Office Memorandum extends the procedure to confirmation, and requires a permanent vacancy to be reserved for an officer whose confirmation case is placed in a sealed cover. The paragraph is two sentences long and carries its own heading in the original, and because it sits after the ad hoc promotion block instead of beside the three categories in paragraph 2, the procedure is often described as written for promotion alone.

One ambiguity sits on its face. The paragraph speaks of the claim for confirmation of an officer under suspension “etc.”, and the abbreviation is in the original. Whether the extension reaches all three categories in paragraph 2 or only suspension is not resolved either in the order or in the department’s later consolidation. The reservation of a permanent vacancy has a practical consequence that outlives the argument: a department that fills every permanent vacancy while a confirmation case is sealed has nothing left to confirm the officer into when the cover is opened.

What the procedure does not reach

The instruction is written around a departmental promotion committee, and it names only two decisions: promotion and confirmation. The table states the position for each adjacent decision, and it is honest about where no instruction exists.

The gaps are gaps in the instruction, not in the law: a department may still refuse a deputation or an empanelment to a servant facing a charge sheet, but it does so under the vigilance clearance orders and on their grounds, and the reasoning and the remedies differ.

Sealed cover against vigilance clearance

A sealed cover is what the committee does with its own recommendation. A vigilance clearance is a certificate the administration issues about the servant. For promotion the two rest on the same three conditions: paragraph 2 of the 1992 order and paragraph 1 of Office Memorandum No. 22034/4/2012-Estt.(D) dated 2 November 2012 list them identically, and paragraph 1 of the 2012 order records that a refusal of clearance on a ground outside that list may not be legally tenable.

Outside promotion the regimes come apart. Office Memorandum No. 104/33/2024-AVD-IA dated 9 October 2024 denies clearance for empanelment and deputation on 12 grounds, several of which, including the currency of a penalty already imposed and the grant of a sanction where the case is pending in the trial court, would not support a sealed cover at a promotion committee. Doly Loyi and the 2024 order are consistent only because they govern different decisions. The upshot for a servant reading a refusal letter is that the ground quoted has to match the decision being taken, and a refusal for promotion on any ground outside the three is bad on the department’s own instruction.

The Indian Administrative Service variant

Department of Personnel and Training letter No. 20011/4/92-AIS-II dated 28 March 2000 governs promotion in the Indian Administrative Service, and it is the same scheme on four different terms. The body is a Screening Committee rather than a departmental promotion committee, and the three categories at its paragraph 11.1 match the central civil services list exactly, as do the assessment mechanics and the superscription at paragraph 11.2.

The second row is the substantive difference. In the central civil services stream a stalled case produces reviews that record the stall; in the Indian Administrative Service the same review is a decision point at which the cover can be opened. The fourth row is the compensating limit: the service that can open a cover early is the service with no ad hoc route at all.

One caution attaches. The letter is titled for the Indian Administrative Service and does not on its face cover the All India Services as a class, so it should not be read across to the Indian Police Service or the Indian Forest Service without checking the instrument for those services. The same caution applies with more force to railway servants, who have their own disciplinary code and their own establishment circulars.

Which document a paragraph number belongs to

A citation to “paragraph 3 of the sealed cover instructions” is ambiguous, and the ambiguity is the department’s own. The Department of Personnel and Training maintains a consolidated information document titled Sealed Cover Procedure, last updated on 30 August 2022, which gathers the 1992 order and the later clarifications into one nine page text. It renumbers everything, and each of its paragraphs carries a bracketed line naming the order it came from.

The renumbering reaches inside a quoted clause. Paragraph 5.3 of the 1992 order grants the exonerated officer the notional benefit “envisaged in para 3 above”; the 2022 document reproduces the same clause with the cross reference reading para 6, because that is where the rule sits in its own text. Both are correct within their own document, and a reader comparing them will conclude that one of them is wrong. The working rule is to name the document with every paragraph number, because “paragraph 3” is the exoneration rule in the 1992 order, the assessment rule in the 2022 consolidation, and the two situation limiting clause in the 2016 order on exoneration after retirement.

Delay, and what a servant can do about it

The instruction supplies no outer limit, so the remedy for a cover held for years is not in the instruction. It is in the Central Administrative Tribunal, where a denied promotion is a service matter within Section 3(q) of the Administrative Tribunals Act, 1985 and the pleading comes out of the department’s own paragraphs: the six monthly reviews under paragraph 4 of the 1992 order either happened or did not, the two year ad hoc consideration under paragraph 5 either was taken up or was not, and the delay either is or is not attributable to the applicant, which is one of the five aspects the appointing authority was required to weigh.

The Central Vigilance Commission treats protracted proceedings as a defect in their own right. Master Circular No. 08/MC/2026, issued on 27 July 2026 in supersession of the Commission’s earlier guidance on timely initiation and finalisation of disciplinary action, prescribes a model time schedule for each stage of a proceeding and rests it on Prem Nath Bali v. Registrar, High Court of Delhi, (2015) 16 SCC 415, decided on 16 December 2015, in which the Supreme Court set six months as the outer limit for concluding a departmental inquiry, extendable to not more than a year where six months is not workable. A sealed cover case is the clearest illustration of why that schedule exists: every month the inquiry takes is a month the servant sits below a junior in an officiating post.

Nothing in the instruction makes a cover lapse with time. A select panel is normally valid for one year and ceases at a year and six months at the outside, but the expiry of the panel does not dispose of the sealed assessment inside the cover: under the 1992 order that assessment is disposed of only by complete exoneration under paragraph 3, or by a penalty or a conviction under paragraph 3.1. A servant told that a cover has become infructuous with the panel should ask which of those two paragraphs was applied.

Related Articles

• Departmental promotion committee
• Promotion in central government service
• Suspension
• Departmental inquiry
• Charge sheet and articles of charge
• CCS (Classification, Control and Appeal) Rules, 1965
• Major versus minor penalty proceedings
• Minor penalty
• Reduction in rank
• Appeal, review and revision under the CCS (CCA) Rules
• Article 311
• Principles of natural justice
• Inquiry officer
• Vigilance clearance
• Central Vigilance Commission
• Chief Vigilance Officer
• Sanction for prosecution
• Prevention of Corruption Act, 1988
• Annual Performance Appraisal Report
• Confirmation in service
• Probation in central government service
• Seniority
• Qualifying service
• Modified Assured Career Progression
• Non-functional upgradation
• Officiating appointment
• Ad hoc appointment
• Deputation in central government service
• Central Staffing Scheme
• Efficiency bar
• Annual increment
• Pay fixation
• Fundamental Rules
• CCS (Pension) Rules, 2021
• Pension calculation
• Central Administrative Tribunal
• All India Services
• Railway employees
• Recruitment rules
• Reinstatement
• Central government employees

External references

• Department of Personnel and Training, Office Memorandum No. 22011/4/91-Estt.(A) dated 14 September 1992: documents.doptcirculars.nic.in
• Department of Personnel and Training, information document on the sealed cover procedure, updated 30 August 2022: dopt.gov.in
• Department of Personnel and Training, Office Memorandum No. 22011/2/99-Estt.(A) dated 21 November 2002, applicability of the sealed cover procedure to a review committee: documents.doptcirculars.nic.in
• Department of Personnel and Training, Office Memorandum No. 22011/2/2002-Estt.(A) dated 24 February 2003, sealed cover procedure after Delhi Jal Board v. Mohinder Singh: documents.doptcirculars.nic.in
• Department of Personnel and Training, Office Memorandum No. 22011/3/2013-Estt.(D) dated 25 January 2016, promotion of government servants exonerated after retirement: documents.doptcirculars.nic.in
• Department of Personnel and Training, Office Memorandum No. 11012/6/2016-Estt.A-III dated 19 January 2017, acquittal by a trial court with an appeal pending: documents.doptcirculars.nic.in
• Department of Personnel and Training, letter No. 20011/4/92-AIS-II dated 28 March 2000, Indian Administrative Service promotion guidelines: dopt.gov.in
• Central Vigilance Commission, Master Circular No. 08/MC/2026 dated 27 July 2026, timely initiation and finalisation of disciplinary action: cvc.gov.in

References

1. Department of Personnel and Training, Office Memorandum No. 22011/4/91-Estt.(A) dated 14 September 1992, promotion of government servants against whom disciplinary or court proceedings are pending, paragraphs 1 to 9.
2. Union of India v. K. V. Jankiraman, (1991) 4 SCC 109, also reported at AIR 1991 SC 2010, decided 27 August 1991.
3. Delhi Development Authority v. H. C. Khurana, (1993) 3 SCC 196; Union of India v. Anil Kumar Sarkar, (2013) 4 SCC 161; Union of India v. Doly Loyi, 2024 INSC 729, Civil Appeal No. 8387 of 2013, decided 24 September 2024.
4. Department of Personnel and Training, Office Memorandum No. 22011/2/99-Estt.(A) dated 21 November 2002, applicability of the sealed cover procedure to a review departmental promotion committee.
5. Department of Personnel and Training, Office Memorandum No. 22011/2/2002-Estt.(A) dated 24 February 2003, paragraphs 3 and 4, issued on Delhi Jal Board v. Mohinder Singh.
6. Department of Personnel and Training, Office Memorandum No. 22011/3/2013-Estt.(D) dated 25 January 2016, promotion of government servants exonerated after retirement, paragraphs 3 to 6.
7. Department of Personnel and Training, Office Memorandum No. 11012/6/2016-Estt.A-III dated 19 January 2017, sealed cover where the government servant is acquitted by a trial court and an appeal is contemplated or filed, citing Bank of India v. Degala Suryanarayana, (1999) 5 SCC 762.
8. Department of Personnel and Training, Office Memorandum No. 22034/4/2012-Estt.(D) dated 2 November 2012, paragraphs 1 and 8; Office Memorandum No. 104/33/2024-AVD-IA dated 9 October 2024, vigilance clearance.
9. Department of Personnel and Training, letter No. 20011/4/92-AIS-II dated 28 March 2000, Indian Administrative Service promotion guidelines, paragraphs 11.1, 11.2, 18.1, 18.2, 19 and 20.
10. Central Civil Services (Pension) Rules, 2021, Rule 8, Explanation 1(b)(i); Central Civil Services (Classification, Control and Appeal) Rules, 1965, Rule 10(2)(b), Rule 11 and Rule 19(i); Fundamental Rule 24; Prem Nath Bali v. Registrar, High Court of Delhi, (2015) 16 SCC 415; Central Vigilance Commission Master Circular No. 08/MC/2026 dated 27 July 2026.