Railway Promotion Circular Upheld Against Tribunal Directions; Earlier Decisions Required Judicial Discipline

A tribunal should maintain judicial discipline when coordinate benches have already decided the same controversy; the High Court set aside directions requiring railway promotion selections to be reconsidered under earlier IREM provisions.

Key Proposition: A tribunal should maintain judicial discipline when coordinate benches have already decided the same controversy; the High Court set aside directions requiring railway promotion selections to be reconsidered under earlier IREM provisions.

• Indian Railway Establishment Manual, Volume I — Paragraphs 204.8 and 204.9 — Promotion to Group-B posts — Whether the Tribunal could direct reconsideration under those paragraphs contrary to the Railway Board circular and prior
• Tribunal decisions — Held, Tribunal order set aside Indian Railway Establishment Code — Rules 123 and 124 — Railway Board’s authority to issue general services instructions — Considered in assessing Circular RBE 10/2025.
• Constitution of India — Article 14 — Equal treatment in promotion selection — Raised in relation to the selection procedure.

Background / Synopsis :

• The dispute concerned selection to Group-B Assistant Engineer posts under the Railway’s 70% promotional quota for eligible Group-C employees.
• Railway Board Circular RBE 10/2025 dated 3 February 2025 prescribed aspects of calling candidates for later selection stages and preparing the panel by seniority, following an earlier circular removing restrictions on the zone of consideration.
• The Central Administrative Tribunal, by common order dated 19 June 2026, directed the Railway authorities to conduct selection for the relevant examinations under paragraphs 204.8 and 204.9 of IREM for the original applicants and, if eligible issue promotion orders within 90 days.
• The petitioners challenged the Tribunal’s order, relying on earlier decisions of the Guwahati Bench and the Bilaspur Circuit Bench which had upheld or applied the circular.

Issues for Consideration :

• Whether the Tribunal’s directions were sustainable in light of the Railway Board circular and earlier Tribunal decisions on the same controversy.
• Whether the selection procedure and the Tribunal’s direction to apply earlier IREM provisions could stand together.
• Whether the affected candidates’ participation and promotional interests had been adequately considered.

Submissions of Parties :

Petitioner / Appellant:

• The petitioners argued that the Tribunal departed from earlier decisions without following judicial discipline or referring the issue appropriately.
• They submitted that the circular prescribed procedure rather than changing eligibility criteria, and that the Railway Board had authority under the Railway Establishment Code.
• They also argued that the Tribunal’s directions affected other candidates and were inconsistent with the selection process already completed.

Respondent / State:

• The Railway authorities contended that the circular was a necessary consequence of allowing all eligible employees to participate and that the selection and promotions had been conducted under the applicable circulars.
• The original applicants maintained that the Railway was bound to follow paragraphs 204.8 and 204.9 of IREM and supported the Tribunal’s directions.

Court's Observations & Analysis :

Re: Issues considered

• The Court considered the relevant IREM provisions, Railway Board circulars, prior Tribunal decisions and the common order under challenge.
• The Court noted that coordinate benches of the Tribunal had already considered the controversy, and found no basis for the Jabalpur Bench to take a different view in the circumstances.
• The Court rejected the Tribunal’s directions requiring the selection to be revisited under paragraphs 204.8 and 204.9 in the manner ordered.
• Held: The common order dated 19 June 2026 in the connected original applications was set aside.

Notable Observations: No separate verbatim quotation included.

Decision & Directions :

• The connected miscellaneous petitions were allowed.
• The common order dated 19 June 2026 passed in O.A. Nos. 200/678/2025 and 200/795/2025 was set aside.
• Separate or dissenting opinion: None.

Legal Provisions Discussed & Precedents Cited :

• Indian Railway Establishment Manual, Volume I — Paragraphs 201.1, 204.8 and 204.9, as discussed: promotional selection and preparation of panels.
• Indian Railway Establishment Code — Rules 123 and 124: Railway Board’s rule-making/administrative authority, as argued.
• Constitution of India — Article 14: equality in public employment, raised in the submissions.
• Tej Prakash v. Rajasthan High Court and Others, 2024 INSC 847 — discussed in submissions concerning selection benchmarks.
• Central Administrative Tribunal, Guwahati Bench — O.A. Nos. 183/2025, 227/2025, 228/2025 and 290/2025, order dated 12 November 2025 — prior decisions concerning the circular.
• Central Administrative Tribunal, Bilaspur Circuit Bench — O.A. No. 644/2025, order dated 29 January 2026 — prior decision relied upon