T.R. Kapur & Ors vs State Of Haryana & Ors on 17 December, 1986
Persons appointed or promoted under a valid Recruitment Rules are seniors to officers of feeder categories. Recruitment Rules can not be amended retrospectively to make such officers juniors to officers who promoted or appointed later on. Service laws can not be amended retrospectively. In Sabarwal, Ajit Singh-I, Ajit Sing-II, Virpal Singh Chauhan cases it was decided to amend service laws prospectively only.
The Apex Court in the Judgement of Radheshyam
Singh (which is not related to Recruitment Rules or seniority but related to selection by Examination ) has clearly stated for prospective amendment of examination provision. Para 10 reproduced.
“10.
The argument advanced by the learned counsel for the respondents that this
process of zone-wise selection is in vogue since 1975 and has stood the test of
time cannot be accepted for the simple reason that it was never challenged by
anybody and was not subjected to judicial scrutiny at all. If on judicial
scrutiny it cannot stand the test of reasonableness and constitutionality it
cannot be allowed to continue and has to be struck down. But we make it clear
that this judgment will have prospective application and whatever selections
and appointments have so far been made in accordance with the impugned process
of selection shall not be disturbed on the basis of this judgment. But in
future no such selection shall be made on the zonal basis. If the Government is
keen to make zone-wise selection after allocating some posts for each zone it
may make such scheme or rules or adopt such process of selection which may not
clash with the provisions contained in Article 14 and 16 of the Constitution of
India having regard to the guidelines laid down by this Court from time to time
in various pronouncements.