Delayed disciplinary entry cannot bar civil servant from IAS promotion, rules division bench
In a significant ruling on administrative fairness, the Orissa High Court has directed the state government to reassess the promotion of Sanjita Das, a retired 1987-batch Odisha Administrative Service (OAS) officer, to the Indian Administrative Service (IAS) cadre.
Despite retiring as Special Secretary, Board of Revenue, in May, Das was denied IAS elevation due to a belatedly recorded disciplinary penalty—a decision the court has now deemed unjust.
The High Court’s order stems from Das’s long-standing contention that a minor 2011 disciplinary punishment—which was only entered into her service record in 2020 (nine years later)—wrongfully disqualified her from IAS promotion in 2019. The court emphasized that the delay in documentation was purely administrative and should not have barred her career progression.
Key Case Details
Period Under Scrutiny: Alleged irregular appointments during her tenure as Additional Executive Officer, Cuttack Municipal Corporation (1995–2000).
Punishment: Withholding of one increment (imposed in 2011 but recorded only in 2020).
Initial Verdict: Her petition was dismissed by a single-judge bench on June 25, 2024.
New Ruling (June 19, 2025): A division bench comprising Chief Justice Harish Tandon and Justice M.S. Raman overturned the decision, stating the delay in recording the penalty should not disadvantage her.
Court’s Key Observations
The bench ruled that the punishment must be treated as served in 2011 and that its late entry in 2020 should not affect her eligibility for the 2019 IAS vacancies.
“Administrative lapses must not deny deserving officers their rightful career progression,” the court asserted.
Impact & Next Steps
The Odisha government has been instructed to reevaluate Das’s promotion eligibility within a stipulated timeframe. If found eligible, she may receive retrospective promotion benefits, even post-retirement.
This landmark judgment reinforces the judiciary’s commitment to fair service record management, ensuring that bureaucratic delays do not undermine an officer’s legitimate career growth.
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