Synopsis

This judgment by a Division Bench of the Bombay High Court allows a writ petition filed by a Chief Medical Officer in the CRPF challenging the rejection of her claim for the Non-Functional Selection Grade (NFSG) – a higher pay scale. The petitioner was overlooked for promotion twice, while her juniors were promoted, on the ground that she did not meet the prescribed benchmark of "Very Good" in her Annual Confidential Reports (ACRs). The court quashed the rejection orders, holding them to be arbitrary and non-speaking. It relied on the settled legal principle that any entry in an ACR that can affect an employee's career prospects, including those below the benchmark, must be communicated to the employee to enable them to make a representation. Failure to do so violates principles of natural justice and Article 14 of the Constitution. The court directed the respondents to grant the petitioner NFSG with all consequential benefits from the due date.

1. Heading for the judgment

Citation: Dr. Anu Verma v. The Secretary (Ministry of Home Affairs) & Ors., Writ Petition No. 5884 of 2005, decided on 18.03.2026 (Bombay High Court - DB)
Coram: Hon'ble Ms. Justice Aarti Sathe and Hon'ble Mr. Justice G. S. Kulkarni (Division Bench)
Core Law: Service Law, Constitutional Law (Article 14), Principles of Natural Justice.

Bombay High Court quashes denial of NFSG promotion to CRPF officer, holds that non-communication of ACR gradings below the benchmark is arbitrary and violates Article 14.

2. Legal framework

This judgment is a significant exposition of service jurisprudence, particularly the rights of employees regarding their Annual Confidential Reports (ACRs).

• Constitutional Law:
  Article 14: The court held that non-communication of entries in ACRs that can adversely affect an employee's career is arbitrary and violates the right to equality and non-arbitrariness.
  Article 226: The petition was filed u

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