In Brief
A military officer challenged his rejection for Permanent Secondment to the Directorate General Quality Assurance (DGQA), arguing that his Technical Assessment Reports should have been considered. The Supreme Court held that the office memorandum governing Permanent Secondment explicitly supersedes all previous instructions and guidelines. Since the memorandum specifies only certain criteria (including completion of a Quality Management Course and 'Above Average' grading) without mentioning Technical Assessment Reports, those reports cannot be an independent consideration. Though TARs may inform Annual Confidential Reports, they are not a criterion under the new memorandum for Permanent Secondment decisions."
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