In Brief
The Supreme Court held that an Annual Confidential Report (ACR) forms an integral part of an officer's service record and must be considered for promotion purposes, even if written with delay. The appellant, a police officer, was promoted to the Indian Police Service based on his complete service record, including previously missing ACRs considered by a Review Select Committee. The High Court had invalidated this promotion, holding that one ACR was written beyond a prescribed period and therefore could not be considered. The Court ruled that administrative delay in writing ACRs—which is beyond the officer's control—cannot prejudice him, and that time-period guidelines for ACRs are directory, not mandatory. The Court approved the Review Committee's promotion decision and allowed the appeal.
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