The Supreme Court dismissed the appeal, upholding that the appellant (a 1976 appointee) was validly redesignated from Junior Field Officer (Group B) to Carpet Training Officer (Group C) in 1978, and subsequent regularization in 2006 as CTO didn’t entitle him to Handicrafts Promotion Officer status or its promotion channel. The Court ruled that cadre classification and scheme-specific redesignation were within the government’s administrative discretion, and the appellant’s acceptance of earlier CAT orders (without challenging the CTO designation) precluded belated claims for HPO benefits under Article 14
Facts Of The Case:
The appellant, Rampat Azad, was appointed as a Junior Field Officer (JFO – Group B) in 1976 at the Carpet Weaving Training Centre, Varanasi, under the All-India Handicrafts Board. In 1978, his post was redesignated as Carpet Training Officer (CTO – Group C) with a downgraded pay scale, while JFOs in the Marketing Scheme were redesignated as Handicrafts Promotion Officers (HPOs) in 1979. Though the government restored his original pay scale in 1997, it retained his CTO designation. The appellant approached the Central Administrative Tribunal (CAT) seeking regularization and promotion benefits equivalent to HPOs. The CAT directed his regularization as CTO in 1999, which was implemented in 2006, but denied HPO status. The appellant challenged this before the Delhi High Court, arguing discrimination under Article 14 since junior JFOs in the Marketing Scheme received HPO designation and promotions. The High Court dismissed his petition, noting the Carpet Scheme’s closure in 2004 rendered CTOs surplus, leaving no promotional vacancies. The Supreme Court upheld this decision, observing the appellant had accepted the 1999 CAT order (regularizing him as CTO) without challenge and that cadre-specific redesignation was a valid administrative decision. The Court declined to grant HPO status, noting the functional differences between the Carpet and Marketing Schemes.
Procedural History:
The case originated with Rampat Azad’s 1997 application (OA No. 2921/1997) before the Central Administrative Tribunal (CAT) challenging his downgraded designation as Carpet Training Officer (CTO). The CAT directed his regularization as CTO in 1999, which was implemented in 2006 after UPSC approval. When promotion avenues remained blocked due to the Carpet Scheme’s 2004 closure, Azad filed a second application (OA No. 2351/2007), wherein the CAT in 2008 directed financial upgradation since promotional posts were unavailable. Dissatisfied, Azad approached the Delhi High Court via writ petition, which upheld the CAT’s orders in the impugned judgment. The Supreme Court’s 2025 decision in Civil Appeal No. 2342/2011 (arising from SLP(C) No. 2629/2012) affirmed the lower courts’ rulings, noting Azad’s failure to challenge the 1999 CAT order accepting CTO status precluded belated claims for Handicrafts Promotion Officer (HPO) benefits. The procedural journey spanned 28 years across three judicial tiers, with the SC ultimately endorsing the government’s cadre classification authority and scheme-specific service conditions.
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Court Observation:
The Court observed that the government’s 1978 decision to redesignate Junior Field Officers (JFOs) in the Carpet Scheme as Carpet Training Officers (CTOs) was a valid administrative exercise of cadre classification power, distinct from the 1979 Handicrafts Promotion Officer (HPO) redesignation for Marketing Scheme JFOs. It emphasized that the appellant’s acceptance of the 1999 CAT order—which directed regularization as CTO without granting HPO status—created an estoppel against later claims for HPO benefits under Article 14. The Bench noted the functional differences between the Carpet and Marketing Schemes justified separate treatment, and the appellant’s failure to challenge the 1999 order precluded belated reclassification demands. Critically, the Court ruled that the Carpet Scheme’s 2004 closure extinguished promotional avenues for CTOs, making financial upgradation under MACP the only viable relief. The judgment underscored that courts cannot mandate cadre mergers or promotions when schemes become defunct, preserving the government’s discretion in service matters.
Final Decision & Judgement:
The Supreme Court dismissed the appeal, upholding the Delhi High Court’s judgment and affirming the Central Administrative Tribunal’s orders. The Court ruled that the appellant, having accepted regularization as a Carpet Training Officer (CTO) in 2006 without challenging the designation, could not subsequently claim entitlement to Handicrafts Promotion Officer (HPO) status or its promotional benefits. The Bench held that the government’s 1978 decision to classify Carpet Scheme employees separately from Marketing Scheme staff was a valid administrative exercise, and the appellant’s belated challenge—filed decades after the redesignation—was barred by acquiescence. While acknowledging the appellant’s long service, the Court emphasized that the closure of the Carpet Scheme in 2004 extinguished promotional avenues, leaving Modified Assured Career Progression (MACP) as the only permissible relief. The judgment reinforced that courts cannot rewrite cadre structures or mandate promotions in defunct schemes, preserving the government’s authority to determine service conditions. All pending applications were disposed of accordingly, with no order as to costs.
Case Details:
Case Title: Rampat Azad (R.P. Azad) vs. Union of India & Ors. Citation:2025 INSC 740 Civil Appeal No.:Civil Appeal No. 2342 of 2011 Date of Judgment:May 20, 2025 Judges/Justice Name: Justice Abhay S. Oka & Justice Ujjal Bhuyan
Download The Judgement Here