Alpana Tiwari vs State Of Chhattisgarh on 9 July, 2025

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“13. In State of Mysore v. G.B. Purohit11, this Court held
that a right to be considered for promotion, is a condition
of service but mere chances of promotion are not. The
rule which merely affects the chances of promotion cannot
be regarded as varying a condition of service. The said
judgment was quoted with approval in later judgment
reported as Ramchandra Shankar Deodhar v. State of
Maharashtra12, wherein this Court held as under: (SCC p.
329, para 15)

“15. … All that happened as a result of making
promotions to the posts of Deputy Collectors division
wise and limiting such promotions to 50 per cent of
the total number of vacancies in the posts of Deputy
Collector was to reduce the chances of promotion
10 (2019) 10 SCC 34
11 1967 SLR 753 (SC)
12 (1974) 1 SCC 317 : 1974 SCC (L&S) 137

available to the petitioners. It is now well settled by
the decision of this Court in State of Mysore v. G.B.
Purohit22 that though a right to be considered for
promotion is a condition of service, mere chances of
promotion are not. A rule which merely affects
chances of promotion cannot be regarded as varying
a condition of service. In Purohit case the district
wise seniority of sanitary inspectors was changed to
Statewise seniority, and as a result of this change the
respondents went down in seniority and became very
junior. This, it was urged, affected their chances of
promotion which were protected under the proviso to
Section 115, sub-section (7). This contention was
negatived and Wanchoo, J. (as he then was),
speaking on behalf of this Court observed: (SLR para

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