In Brief
Air Commodore Naveen Jain was commissioned in the Indian Air Force in 1981 and promoted to Air Commodore in 2011. When considered for promotion to Air Vice Marshal against five vacancies, he ranked first in merit but third in seniority on the select list. Two vacancies arose after his superannuation date, so he was not promoted. He challenged the promotion policy, arguing that a merit-based selection followed by seniority-based ranking violated Articles 14 and 16 of the Constitution. The Supreme Court dismissed his appeal, holding that the two-stage process (merit-based shortlisting within a zone of consideration, followed by seniority-based final promotion) constitutes valid 'seniority-cum-merit' promotion. The Court rejected his challenge both on the merits of the policy and on the ground that he was estopped from challenging it after participating in the selection process.
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