Seniority in central government service

Seniority is a government servant’s relative rank, or inter se position, within a grade or cadre, and in the central civil services it runs from the date of regular appointment to that grade. The governing instrument is Department of Personnel and Training Office Memorandum No. 20011/1/2008-Estt.(D) dated 11 November 2010, titled “Instructions and Guidelines on Seniority”: 16 pages of consolidated instructions followed by typed copies of 24 earlier Office Memoranda across pages 17 to 81. Paragraph 1 fixes its reach at Central Civil Services and civil posts, excluding services and posts for which separate principles have been issued, which is why the All India Services and the defence services follow their own rules.

Seniority decides the order in which officers enter the field of consideration for promotion, and in many cadres it also governs the order of choice in postings, allotment of quarters and similar benefits. It does not decide the promotion itself. Since 8 February 2002 the Departmental Promotion Committee grades officers only fit or unfit against a benchmark, and those found fit are placed in the panel in feeder-grade seniority order, so merit no longer reorders the panel in the central civil services.

The single most contested question in the field is how a direct recruit ranks against a promotee appointed in the same period. That rule changed twice in a decade. The Supreme Court tied the direct recruit’s position to the recruitment year in Union of India v. N.R. Parmar, (2012) 13 SCC 340, decided on 27 November 2012; a three-judge bench overruled that in K. Meghachandra Singh v. Ningam Siro, (2020) 5 SCC 689, decided on 19 November 2019; and Office Memorandum No. 20011/2/2019-Estt.(D) dated 13 August 2021 withdrew the implementing order of 4 March 2014 and rewrote departmental practice around the year of actual appointment.

This article sets out the governing order and its scope, the general principle and the two source rules, rotation of quota with the department’s own worked illustration, the roster and its starting point, the full course of the N.R. Parmar litigation and the pending Constitution Bench reference, the treatment of absorption and deputation, technical resignation, the relationship with promotion, consequential seniority for Scheduled Caste and Scheduled Tribe officers, penalties and suspension, delayed joining, and the special categories the consolidated instructions deal with at paragraphs 4.1 to 4.12.

The governing order and its scope

Office Memorandum No. 20011/1/2008-Estt.(D) dated 11 November 2010 is a compilation, not a fresh code. Its heading names the five instruments it draws together: the general principles in Ministry of Home Affairs Office Memorandum No. 9/11/55-RPS dated 22 December 1959, Office Memorandum No. 35014/2/80-Estt.(D) dated 7 February 1986 on rotation and carry-forward, the consolidated orders in Office Memorandum No. 22011/7/86-Estt.(D) dated 3 July 1986, Office Memorandum No. 20011/5/90-Estt.(D) dated 4 November 1992 delinking seniority from confirmation, and the clarification in Office Memorandum No. 20011/1/2006-Estt.(D) dated 3 March 2008 on the meaning of the word “available”.

Each underlying order remains in force. The compilation quotes the source Office Memorandum against each instruction and reproduces 24 of them in an annexure, which matters in practice because a tribunal will look at the original order and not the compilation when the two are read differently.

Paragraph 1 limits the instructions to Central Civil Services and civil posts, “except such Services and Posts for which separate principles have already been issued or may be issued by the Government”. Seniority in a public sector undertaking, an autonomous body or a bank is governed by the regulations of that organisation rather than by these instructions, and the All India Services follow the year-of-allotment scheme under their own rules.

The general principle: appointment, not vacancy

Seniority accrues from the date of regular appointment to the grade. It does not accrue from the date the vacancy arose, from the year the recruitment process was initiated, or from the date of an offer of appointment that has not been acted on. Paragraph 6(ii) of Office Memorandum No. 20011/2/2019-Estt.(D) dated 13 August 2021 states the position without qualification: the seniority of direct recruits and promotees “stands delinked from the vacancy or year of vacancy”. Paragraph 6(iii) locates the source of legitimacy in the date of joining against a vacancy, whether or not that vacancy arose in an earlier year.

The principle behind it is older than the order. In Jagdish Ch. Patnaik v. State of Orissa, (1998) 4 SCC 456, the Supreme Court held that seniority cannot be claimed from a date on which the incumbent was not yet borne in the cadre. K. Meghachandra Singh, decided on 19 November 2019, expressly approved that declaration of the law at paragraph 40 and disapproved the contrary reasoning in N.R. Parmar.

A separate rule, now historical but still quoted, tied seniority to the order of confirmation where confirmation happened in a different order from the original merit list. That was discontinued with effect from 4 November 1992 by Office Memorandum No. 20011/5/90-Estt.(D) of that date, and paragraphs 2.1 and 2.2 of the consolidated instructions record the discontinuance for direct recruits and promotees alike. Confirmation in service has had no bearing on seniority for more than three decades.

Direct recruits

The relative seniority of direct recruits is the order of merit in which they were selected on the recommendation of the Union Public Service Commission, the Staff Selection Commission or another selecting authority, with persons appointed as a result of an earlier selection ranking senior to those appointed as a result of a subsequent selection. Paragraph 2.1 of the consolidated instructions puts it in those words, and the date on which an individual recruit reports for duty is irrelevant to the inter se order within a panel.

Three clarifications qualify that rule, and each answers a question that arises often enough to have produced its own paragraph.

Candidates nominated later from a reserve panel take their place by the consolidated merit given by the Commission or the recruiting agency, under paragraph 2.1.1, subject to the discipline on operating reserve panels in Office Memorandum No. 41019/18/97-Estt.(B) dated 13 June 2000.

Where a recruiting agency sends two separate panels bearing the same date, paragraph 2.1.2 prescribes a three-step tie-break: the chronology of the recommendation letters, then the chronology of the interview board reports, then the chronology of the requisitions made by the ministries. For recruitment through an examination the criterion remains the date of publication of the results.

Where candidates are selected for different posts in the same grade requiring different qualifications, for instance assistant lecturers in history, economics, physics and chemistry, paragraph 4.9 requires the Commission to recommend them in a single consolidated order of merit, and seniority follows the order of names in that consolidated list.

Promotees

The seniority of an officer promoted on the recommendation of a Departmental Promotion Committee is the same in the promoted grade as it was in the feeder grade. Paragraph 2.2 of the consolidated instructions applies that to both the selection and the non-selection method, for every officer assessed as fit, and adds two riders. Persons appointed as a result of an earlier selection are senior to those appointed as a result of a subsequent selection. A person considered unfit and superseded by a junior does not, on being found suitable and promoted later, take seniority in the higher grade over the juniors who superseded him.

That second rider is the sharp edge of the rule. A single adverse assessment permanently reorders an officer against contemporaries, because the later promotion carries the later date and cannot reach back over the officers who went up first.

Where a grade is filled by promotion from more than one feeder grade, the treatment turns on whether quotas exist. Paragraph 2.2.1 applies where they do: eligible officers are listed separately in the order of their seniority in their respective grades, and those assessed as fit are interpolated in the ratio prescribed for each feeder grade in the recruitment rules. Paragraph 2.2.2 applies where no quota has been fixed, usually because the promotion grade holds too few posts for a ratio to work. A combined eligibility list is then prepared on three parameters: the date of completion of the qualifying service prescribed in the recruitment rules in the feeder grade, then the date of completion of qualifying service in the feeder-to-feeder grade, with the inter se seniority of officers from each feeder grade maintained throughout.

Rotation of quota between direct recruits and promotees

Where a grade is filled from both sources in a ratio fixed by the recruitment rules, the vacancies of a year are shared between them by rotation against a roster, in that ratio. Paragraph 2.4 of the consolidated instructions states the rule and paragraph 2.4.1 governs what happens when the ratio cannot be worked because one source has not delivered.

Rotation operates only to the extent that candidates are actually available. To the extent direct recruits are not available, the promotees are bunched together at the bottom of the seniority list, below the last position up to which seniority can be fixed by rotation against the direct recruits who did become available. The unfilled direct-recruitment quota vacancies are carried forward and added to the corresponding direct-recruitment vacancies of the next year. In that later year, seniority between the two sources is worked by rotation for the number of vacancies belonging to each under that year’s quota, and the additional direct recruits selected against the carried-forward vacancies are placed en bloc below the last promotee in the later year’s list. The same principle applies where promotion quota vacancies are the ones carried forward.

The department supplies its own illustration, and it is worth reproducing because it settles the placement question that argument usually turns on. The grade is filled 50% by promotion and 50% by direct recruitment, ten vacancies arise in each of 1986 and 1987, and two direct-recruitment vacancies of 1986 remain unfilled until 1987.

Three readings follow from the table. The 1986 block ends with two promotees in succession at positions 7 and 8, because only three direct recruits were available to rotate against five promotees. The two carried-forward direct recruits appear as D6 and D7 at the bottom of 1987 rather than anywhere in the 1986 block, which is the point the Supreme Court said N.R. Parmar had overlooked. And a promotee of 1986 at position 8 stands senior to a direct recruit of 1987 at position 10 even though both were, in the department’s paperwork, filling vacancies of adjacent years.

Two administrative controls sit alongside the rule. Paragraph 2.4.3 of the 1986 consolidated orders requires a vacancy register giving a running account of vacancies arising and being filled from year to year, in a prescribed proforma. Paragraph 2.4.4 of that order attacks the practice of under-reporting direct-recruitment vacancies: promotees are treated as regular only to the extent that direct-recruitment vacancies were actually reported to the recruiting authority on the basis of the prescribed quota, and any excess promotees beyond the promotion quota computed against the notified direct-recruitment figure are treated as ad hoc promotees only. An ad hoc promotion earns no seniority in the higher grade.

The roster: starting point and when a new one begins

The starting point in the recruitment roster is the mode of recruitment whose selection process was completed first, under paragraph 2.4.3 of the consolidated instructions of 11 November 2010, drawn from Office Memorandum No. 28011/6/76-Estt.(D) dated 24 June 1978. Completion is defined by mode.

A new roster has to be started in two situations under paragraph 2.4.4: from the date the recruitment rules are notified in the gazette, and whenever an amendment to those rules changes the percentage allotted to the various modes of recruitment. Continuing an old roster across a change of ratio is a common cadre-management error and it corrupts every subsequent placement.

From N.R. Parmar to K. Meghachandra Singh

The current rule is that rotation of quota decides how many vacancies of a recruitment year belong to each source, while inter se seniority is reckoned by the year in which each person was actually appointed. Getting to that sentence took four rounds, and the older rule is still quoted widely enough that a seniority list drawn on it will be challenged.

K. Meghachandra Singh was made prospective, with one carve-out that is regularly missed. Paragraph 40 of the order protects inter se seniority already fixed on N.R. Parmar and applies the decision prospectively “except where seniority is to be fixed under the relevant Rules from the date of vacancy or the date of advertisement”. Where a service rule itself keys seniority to the vacancy date, that rule continues to operate and the judgment does not displace it.

The 2021 Office Memorandum turns the ruling into four transitional categories at paragraph 7. Cases already decided under the 4 March 2014 order are not to be reopened. Direct recruits and promotees appointed between 27 November 2012 and 18 November 2019 whose inter se seniority could not be finalised by 18 November 2019 remain governed by the 1986 orders read with the 2014 order, unless a court or tribunal has directed otherwise. Where a recruitment process began before 19 November 2019 and some appointments were made before that date and some after, the same older combination applies, so that one selection is not split across two regimes. Everything initiated on or after 19 November 2019 follows the new rule.

That third category, paragraph 7(iii), is itself contested. The Delhi High Court has held that where a seniority list is being drawn up for the first time after K. Meghachandra Singh, it must conform to that judgment irrespective of the date of recruitment, and that paragraph 7(iii) is erroneous in law to the extent it directs otherwise. An employee whose list was finalised after 19 November 2019 on the strength of that paragraph has a live ground of challenge before the Central Administrative Tribunal.

Six principles govern the fresh cases, under paragraph 6 of the 2021 order. Rotation of quota continues to determine how many vacancies of a recruitment year go to each source, the recruitment year being the year the vacancy arises. Inter se seniority is reckoned by the year in which a person is borne in the cadre or the formal appointment order is issued. Recruitment and appointment are read harmoniously, so determination turns on actual appointment rather than initiation of the process. The date of joining against a vacancy is the source of legitimacy, whether or not the vacancy arose in an earlier year. Rotation stops once the available direct recruits and promotees of that year have been assigned their slots. And where no direct recruit is available in a year, the available promotees are bunched together in the order of the approved promotion panel, with the mirror rule where no promotee is available.

Absorption, deputation and transfer

Deputation does not disturb parent-cadre seniority and does not create seniority in the borrowing organisation. The lien is retained, the officer continues to be borne on the parent cadre, and the deputation itself sets nothing back. Absorption is governed differently, and the consolidated instructions treat it at paragraph 3 under the heading “Seniority of absorbees”, the method of recruitment formerly called transfer having been renamed absorption by Office Memorandum No. AB.14017/2/97-Estt.(RR) dated 25 May 1998.

The relative seniority of persons appointed by absorption to a central service from a subordinate office or another department is determined by the order of their selection for absorption, under paragraph 3.1. Where absorption is against a specific quota in the recruitment rules, paragraph 3.2 puts absorbees into the same rotation of vacancies as direct recruits and promotees, on the quotas reserved for the three sources, and applies the carry-forward and bunching rule of paragraph 2.4.1 to them without change. Where two or more persons are selected from different sources on the same occasion and the selection is spread over several days, paragraph 3.3 requires the approving authority to record their inter se order of merit.

Paragraph 3.4.1 deals with the common case of an officer taken first on deputation and absorbed later, where the recruitment rules provide for deputation or absorption. Seniority in the absorbing grade normally counts from the date of absorption. If, on the date of absorption, the officer was already holding the same or an equivalent grade on a regular basis in the parent department, that regular service counts too, and seniority is given from the date of holding the post on deputation or the date of regular appointment to the same or equivalent grade in the parent department, whichever is earlier. Office Memorandum No. 20011/1/2000-Estt.(D) dated 27 March 2001 made that change and gave it effect from 14 December 1999; the 1986 formulation had used the later of the two dates, which was the less favourable reading. Equivalence of grade is settled by the analogous-posts criteria in Office Memorandum No. 14017/27/75-Estt.(D) dated 7 March 1984. Paragraph 3.5 extends the identical treatment to a person transferred and absorbed directly without any preceding deputation.

The rule that most published guidance still carries has been deleted. The 1959 general principles placed an officer whose transfer was not strictly in public interest below all officers regularly appointed to the grade on the date of absorption. Paragraph 3.4.3 of the consolidated instructions records that the provision was reviewed and now stands deleted, on the reasoning that no situation could be envisaged in which an absorption is not in public interest. Repeating the pre-2001 rule as the current position on own-request moves is a straightforward error.

What survives is a narrower rule about downward moves. Paragraph 4.6 governs an officer who asks to be transferred to a lower post under Fundamental Rule 15(a)(2). Such a transfer is neither a penalty nor a transfer in the public interest, and restoring the officer to the top of the lower grade would nullify the purpose of the move, so the officer is placed below all officers regularly appointed to the lower grade on the date of transfer.

Technical resignation

A technical resignation carries pay, leave, provident fund and pensionable service into the new post, and carries no seniority. The employee is a fresh entrant in the new cadre and takes seniority from the date of joining it, which in practice means becoming junior-most. Seniority in the old post survives only through the retained lien under Fundamental Rule 9(13), which must be resigned within two years of joining the new post, or three in exceptional cases, unless the officer reverts.

The two positions are consistent rather than contradictory. The lien exists so the officer can go back; it does not travel forward. An officer who clears a fresh selection for a better post keeps the pay and pension continuity built up over a career and starts at the bottom of the new cadre’s list, and that trade is usually the decisive consideration. The mechanics are in technical resignation and lien.

Seniority and promotion

Seniority fixes the field of consideration for promotion and, since 8 February 2002, also fixes the order of the resulting panel. Office Memorandum No. 35034/7/97-Estt.(D) of that date, titled “Procedure to be observed by Departmental Promotion Committees, No supersession in ‘selection’ promotion”, dispensed with the distinction between selection by merit and selection-cum-seniority, renamed the mode of promotion “selection” in every case, and expressed the degree of selectivity solely through the benchmark, Very Good or Good. Paragraph 3.2 directs the committee to grade officers as fit or unfit only, to include only those found fit, and to arrange them in the panel in the order of their inter se seniority in the feeder grade. Paragraph 3.1 records the decision that “there should be no supersession in matter of ‘selection’ (merit) promotion at any level”.

Before that order the position was the opposite at the higher levels. Under the guidelines then in force, an officer graded Outstanding superseded one graded Very Good, and Very Good superseded Good, with those on the same grading ordered by feeder-grade seniority. That regime ended more than two decades ago, and material describing merit-based supersession as current practice in the central civil services is describing the pre-2002 rule.

Two things still separate seniority from promotion. Being in the field of consideration is not a right to be promoted: an officer graded unfit against the benchmark is left out of the panel altogether, and the supersession that follows is permanent as to seniority under paragraph 2.2 of the consolidated instructions. And eligibility conditions in the recruitment rules operate independently of position on the list, including the requirement to hold the feeder post on a regular basis and to have completed the prescribed qualifying service in it. The committee’s own procedure, the zone of consideration and the sealed cover cases are set out in departmental promotion committee, and the reports it reads in annual performance appraisal report.

None of this touches the Modified Assured Career Progression scheme, which grants a financial upgradation after 10, 20 and 30 years of regular service without a vacancy and without a committee, and is not a functional promotion. Seniority governs the functional promotion; the scheme is a pay fallback where that promotion does not come. Pay fixation on promotion covers what happens to pay once it does.

Consequential seniority for Scheduled Caste and Scheduled Tribe officers

A Scheduled Caste or Scheduled Tribe government servant promoted by virtue of the rule of reservation is entitled to consequential seniority. Paragraph 2.3 of the consolidated instructions, drawn from Office Memorandum No. 20011/1/2001-Estt.(D) dated 21 January 2002, states the effect directly: a general or Other Backward Class candidate promoted through a later Departmental Promotion Committee is placed junior to a Scheduled Caste or Scheduled Tribe government servant promoted through an earlier committee, even though the earlier promotion came by the rule of reservation.

The clarification appended to that paragraph draws a line that is often blurred in argument. Roster points in the reservation roster identify which vacancy goes to which category. They are not a determinant of an officer’s position within a panel recommended by the committee. Position within the panel is fixed by feeder-grade seniority among those graded fit, under the 8 February 2002 guidelines.

Penalties, suspension and seniority

A penalty of reduction to a lower service, grade, post or time scale must specify two things in the order itself, under paragraph 4.2.4 of the consolidated instructions: the period of reduction, unless the intention is that it be permanent or for an indefinite period, and whether on re-promotion the government servant will regain the original seniority held before the penalty. An order silent on either point is defective and is the usual ground of appeal on this head.

Where the reduction is for a specified period and does not operate to postpone future increments, paragraph 4.2.5 fixes seniority in the higher grade at what it would have been but for the reduction, unless the punishment order provides otherwise. Where the reduction does postpone future increments, paragraph 4.2.6 fixes seniority on re-promotion by giving credit for the period already served in the higher grade. The distinction between the two is drawn in the penalty order and cannot be supplied afterwards by the establishment section. The penalties themselves are listed in CCS (CCA) Rules.

Suspension is treated separately. Paragraph 4.2.1, from Office Memorandum No. 22011/4/91-Estt.(A) dated 14 September 1992, applies where an officer under suspension is completely exonerated on conclusion of the departmental proceeding and the suspension is held to have been wholly unjustified. Such an officer is to be promoted in the first vacancy that can be made available, seniority in the higher grade is fixed as if the promotion had been made according to the position in the select list, and the period during which a junior officer was promoted counts towards the minimum service prescribed for eligibility. Exoneration falling short of “completely exonerated”, or a suspension that was justified on the material available, does not attract the paragraph.

Paragraph 4.2.2, from Office Memorandum No. 20011/2/92-Estt.(D) dated 3 November 1995, covers the officer recommended for promotion by a committee despite a minor penalty in force. The promotion is made on that recommendation only after the penalty expires, and seniority is then fixed by the officer’s position in that panel rather than by the later date of actual promotion.

Delay in joining after selection

An offer of appointment must specify the period, normally not more than one or two months, after which it lapses automatically if the candidate does not join. Paragraph 4.4 of the consolidated instructions, from Office Memorandum No. 9/23/71-Estt.(D) dated 6 June 1978 read with Office Memorandum No. 35015/2/93-Estt.(D) dated 9 August 1995, allows an extension on request but not beyond three months in the ordinary case, and in no case beyond six months from the date of issue of the original offer. An offer lapses automatically at six months.

A candidate who joins inside that six-month window has seniority fixed under the normal rules “without any depression of seniority”. A lapsed offer is not ordinarily revived, and where it is revived on grounds of public interest the Union Public Service Commission must be consulted first. The revived candidate is placed below everyone who joined within the prescribed period. If candidates of the next selection examination have already joined, the person goes to the bottom of the next batch, and in the case of recruitment by examination is allotted to the next year’s batch and placed at its bottom. A delay of a few weeks costs nothing; a delay past six months can cost a full year of the list.

Surplus, re-employed and other special categories

Paragraphs 4.1 to 4.12 of the consolidated instructions deal with the categories that do not fit the two main sources. They are short, they are frequently the whole answer to an individual query, and the substance is set out below.

Paragraph 4.3.4 removes one large class from the surplus-staff rules altogether: they do not apply to persons appointed on the recommendation of the Union Public Service Commission to posts recruited through the Commission, whose seniority is decided on merits in consultation with it.

Common misconceptions

Five statements circulate widely and none of them is the current rule.

That an employee who moves cadre at their own request always goes to the bottom. That provision was deleted by Office Memorandum No. 20011/1/2000-Estt.(D) dated 27 March 2001 and paragraph 3.4.3 of the consolidated instructions records the deletion. The bottom-of-the-grade rule now applies only to a transfer to a lower post at the officer’s own request under Fundamental Rule 15(a)(2), under paragraph 4.6.

That a junior can supersede a senior at a Departmental Promotion Committee on comparative merit. Not since 8 February 2002 in the central civil services, where those graded fit go into the panel in feeder-grade seniority order.

That a direct recruit’s seniority relates back to the year the recruitment process was initiated. That was the rule between 27 November 2012 and 18 November 2019, and the Supreme Court overruled it on 19 November 2019. The order that implemented it, dated 4 March 2014, was withdrawn as non est on 13 August 2021.

That an officer on deputation loses ground at home. The lien and the parent-cadre seniority are protected throughout, and on eventual absorption the deputation period itself counts under paragraph 3.4.1.

That confirmation improves a person’s place in the list. Seniority was delinked from confirmation with effect from 4 November 1992 by Office Memorandum No. 20011/5/90-Estt.(D) of that date, and a probationer’s position is set by the mode and date of appointment, as probation in central government service sets out.

Related Articles

• Departmental Promotion Committee
• Promotion
• Extraordinary leave
• Annual performance appraisal report
• Confirmation in service
• Probation in central government service
• Technical resignation
• Lien
• Deputation in central government
• Foreign service
• Absorption
• Seniority list
• Compassionate appointment
• Reservation roster in promotion
• Recruitment rules
• Staff Selection Commission
• Union Public Service Commission
• Central Administrative Tribunal
• CCS (CCA) Rules, 1965
• Charge sheet and articles of charge
• Departmental inquiry
• Appeal, review and revision under the CCS (CCA) Rules
• Sealed cover procedure
• Non-functional upgradation
• Modified Assured Career Progression
• MACP vs promotion
• Pay fixation on promotion
• Stepping up of pay
• Notional pay fixation
• Pay fixation
• Annual increment
• Basic pay
• Pay matrix
• Grade pay
• Qualifying service
• Joining time
• Fundamental Rules
• Central Secretariat Service
• All India Services (Revised Pay) Rules, 2016
• Assistant Section Officer (ASO) salary
• Section Officer (SO) salary
• Under Secretary (US) salary
• SSC CGL salary
• IAS salary
• Superannuation
• Voluntary retirement
• Premature retirement
• Central government pension
• Take-home salary for central government employees
• 7th Central Pay Commission
• Department of Personnel and Training
• Central government employees in India

External references

• Department of Personnel and Training
• DoPT: Instructions and Guidelines on Seniority (index of the 2010 compilation)
• DoPT: establishment acts and rules
• Union Public Service Commission
• Staff Selection Commission
• Supreme Court of India
• The Gazette of India

References

1. Department of Personnel and Training, Office Memorandum No. 20011/1/2008-Estt.(D) dated 11 November 2010, “Instructions and Guidelines on Seniority” (consolidated instructions, paragraphs 1 to 4.12, with 24 Office Memoranda annexed at pages 17 to 81).
2. Ministry of Home Affairs Office Memorandum No. 9/11/55-RPS dated 22 December 1959 (general principles for determining seniority).
3. Office Memorandum No. 35014/2/80-Estt.(D) dated 7 February 1986 (rotation of quota, carry-forward and bunching) and Office Memorandum No. 22011/7/86-Estt.(D) dated 3 July 1986 (consolidated orders on seniority).
4. Office Memorandum No. 20020/7/80-Estt.(D) dated 29 May 1986 and Office Memorandum No. 20011/1/2000-Estt.(D) dated 27 March 2001 (seniority of persons absorbed after being on deputation; deletion of the not-in-public-interest provision, effective 14 December 1999).
5. Office Memorandum No. 20011/5/90-Estt.(D) dated 4 November 1992 (delinking seniority from confirmation) and Office Memorandum No. 20011/1/2006-Estt.(D) dated 3 March 2008 (clarification of the term “available”).
6. Office Memorandum No. 22011/4/91-Estt.(A) dated 14 September 1992, Office Memorandum No. 20011/2/92-Estt.(D) dated 3 November 1995 and Office Memorandum No. 35034/7/97-Estt.(D) dated 8 February 2002 (suspension and penalty cases; no supersession in selection promotion).
7. Office Memorandum No. 20011/1/2001-Estt.(D) dated 21 January 2002 (consequential seniority on promotion by the rule of reservation) and Office Memorandum No. 14014/6/94-Estt.(D) dated 9 October 1998 (Compassionate Appointment Scheme, paragraph 15).
8. Office Memorandum No. 20011/1/2012-Estt.(D) dated 4 March 2014 (recruitment-year definition after N.R. Parmar, since withdrawn) and Office Memorandum No. 20011/2/2019-Estt.(D) dated 13 August 2021 (revised instructions after K. Meghachandra Singh, paragraphs 6 and 7).
9. Jagdish Ch. Patnaik v. State of Orissa, (1998) 4 SCC 456; Union of India v. N.R. Parmar, (2012) 13 SCC 340, decided 27 November 2012; K. Meghachandra Singh v. Ningam Siro, (2020) 5 SCC 689, Civil Appeal Nos. 8833-8835 of 2019, decided 19 November 2019; Hariharan v. Harsh Vardhan Singh Rao, decided 14 December 2022 (reference to a five-judge bench).