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Supreme Court of India 2022-06-16 allowed

Krishna Rai (Dead) through Lrs & Ors vs Banaras Hindu University through Registrar & Ors

Bench: 3 — Vikram Nath

In Brief

The Supreme Court examined whether statutory service rules for promotion in Banaras Hindu University can be overridden by principles of estoppel and acquiescence. The University's Board of Examiners introduced an interview and weighted scoring system (totalling 100 marks) for promotion of Class-IV employees to Class-III, departing from the statutory Manual which prescribed only a typing test and written departmental test, with seniority as the basis. The Court held that statutory service rules prescribed by the rule-making authority cannot be altered by subordinate bodies and that estoppel cannot prevail against law. Setting aside the Division Bench's order, the Court allowed the appeal, directing the University to conduct fresh promotions strictly in accordance with the statutory rules and extend consequential benefits to all eligible appellants, including legal heirs of those deceased.

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Administrative Law Service Rules Promotion Procedure Estoppel Statutory Authority University Administration Principle of Estoppel

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