In Brief
An Armed Forces Medical Services officer challenged his non-promotion to the rank of Brigadier, claiming he was wrongly denied marks for a Ph.D. degree from Berhampur University, postgraduate training, and a Master's degree. The Armed Forces Tribunal dismissed his case. The Supreme Court upheld the dismissal, holding that under the applicable 2006 promotion policy, Ph.D. degrees qualify for marks only if recognised by the Medical Council of India, and the postgraduate training certificate lacked evidence of formal study leave and structured training as required. The Court affirmed that employers may amend promotion policies at any time and need not wait for stipulated review periods.
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