In Brief
Colonel I.V.S. Gahlot, an officer in the Armed Forces Medical Services, was not selected for promotion to Brigadier rank. He challenged the Promotion Board's decision, claiming he was wrongly denied marks for: (1) a Ph.D. in Anthropology from Berhampur University; and (2) post-graduate training in Pediatrics. The Supreme Court upheld the dismissal, holding that the revised 2006 promotion policy validly restricted Ph.D. marks only to degrees recognized by Medical Council of India in its statutory First Schedule, and that the training certificate did not evidence a formal, structured two-year study leave programme as required by the policy.
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