The High Court of Manipur held that when statutory or institutional rules require preparation and notification of inter-se-seniority lists as a precondition for promotion the authorities must expedite the process and failure to do so justifies judicial directions The Court clarified that the National Medical Commission Rules which came into effect after the institutional rules will not apply retroactively to ongoing promotion processes under those rules This judgment reaffirms the primacy of institution-specific promotion rules and the court’s power to issue writs for timely compliance it is binding authority within Manipur and persuasive for similarly placed institutions
Summary
| Category | Data |
|---|---|
| Case Name | WP(C)/418/2025 of Teachers Association JN Institute of Medical Sciences, Imphal Vs State of Manipur Another |
| CNR | MNHC010014112025 |
| Date of Registration | 19-05-2025 |
| Decision Date | 10-09-2025 |
| Disposal Nature | Disposed of with direction |
| Judgment Author | Hon’ble Mr. Justice Ahanthem Bimol Singh |
| Court | High Court of Manipur |
| Precedent Value | Binding within Manipur; Persuasive for other institutions with similar rules |
| Type of Law | Service Law / Administrative Law |
| Questions of Law |
|
| Ratio Decidendi |
The Court held that, under the JNIMS Rules, 2020, prompt finalisation of inter-se-seniority lists is mandatory before promotions can be effected. Authorities are bound to notify such lists after reasonable opportunity to stakeholders. The National Medical Commission Rules, coming into force after the said promotion rules, have no bearing on ongoing promotion exercises under the earlier framework. Mandamus can be issued to expedite the process. |
| Facts as Summarised by the Court |
The faculty at JNIMS, including assistant and associate professors, were not promoted for long periods due to non-finalisation of seniority lists. Authorities were delayed in following their own rules (2020 Scheme). Petitioners sought directions for preparation of seniority lists, for promotions to be effected under those lists and rules, and for non-application of post-2022 NMC Rules. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts and authorities in the State of Manipur regarding JNIMS and similar institutional promotion rules. |
| Persuasive For | High Courts in other states dealing with analogous situations in state medical institutes or universities having their own promotion schemes/rules. |
| Follows | Institutional practice and procedural fairness principles in service law. |
What’s New / What Lawyers Should Note
- The High Court expressly directed that the National Medical Commission (NMC) Rules, effective from 17.02.2022, shall have no bearing on promotions governed by the JNIMS Rules, 2020.
- Mandamus was issued compelling authorities to finalise the inter-se-seniority list and effect promotions strictly according to the institutional rules within a stipulated time.
- Emphasised the right of stakeholders to submit objections before finalisation of seniority lists.
- The judicial direction mandates time-bound compliance, ensuring faculty cannot be indefinitely deprived of career advancement due to administrative delays.
Summary of Legal Reasoning
- The Court identified a statutory duty upon the authorities under the JNIMS Rules, 2020, especially Rules 4(b), 5(A), 5(B), and 6, to prepare and finalise inter-se-seniority lists as a prerequisite for considering faculty promotions.
- It found no factual disputes—both sides accepted that process for finalisation was initiated but not completed.
- The Court concluded that institutional rules (Rules of 2020) requiring finalisation of seniority list and laying down promotional criteria must be fully complied with. Delay deprives faculty of legitimate career rights.
- The authorities’ reliance or future intention to apply NMC Rules (2022) could not override the binding effect of existing institutional rules for ongoing promotions.
- The Court thus directed:
- Seniority list to be finalised within two months, after hearing objections;
- All further promotion steps to be taken under 2020 Rules, not NMC Rules;
- Promotion process to be completed within two months after notification of the seniority list.
Arguments by the Parties
Petitioner
- Authorities failed to finalise inter-se-seniority list, causing eligible faculty to be deprived of promotion under the 2020 Rules.
- Many faculty members are nearing retirement without availing a single promotion.
- Sought judicial directions to expedite the process, guarantee fairness (including right to file objections), and ensure promotions occur only under the institutional scheme — without the application of NMC Rules coming into force later.
Respondent No. 2 (JNIMS)
- Authorities have already initiated the process for determination of seniority, issuing a relevant order adopting prescribed norms for the exercise.
- Action for seniority fixation is ongoing, and directions may be passed for expediting process.
Respondent No. 1 (State of Manipur)
- Sought further time to file a counter affidavit (no specific objection or counter-argument detailed in the judgment).
Factual Background
The petitioner Teachers Association (and an individual faculty member) from JN Institute of Medical Sciences, Imphal, filed a writ petition seeking directions to compel respondents to finalise the inter-se-seniority list of assistant and associate professors, and to then grant promotions under the Time Scale Promotion Scheme for Teachers of JNIMS Rules, 2020. Faculty members had waited years, some approaching retirement, without promotion due to this delay. The authorities had begun the prescribed process (including adoption of specific norms and inviting objections) but had not yet issued the final list, resulting in delay of promotions. Petitioners also sought that the National Medical Commission Rules (brought into force in 2022) should not be applied to this process.
Statutory Analysis
- JNIMS Rules, 2020 (Time Scale Promotion Scheme Rules):
- Rule 4(b): Promotion must be on the basis of a common eligibility list (inter-se-seniority) as of 1st February of the vacancy year.
- Rule 5(A): Sets criteria for promotion from Associate Professor to Professor, including percentage of posts to be promoted and compliance with requirements of Medical Council of India regulations.
- Rule 5(B): Sets criteria for promotion from Assistant Professor to Associate Professor.
- Rule 6: Mandates preparation of seniority list of eligible candidates upon which promotions are to be based.
- National Medical Commission Rules (2022): Court clarified these do not apply to the current promotion exercise governed by the 2020 institutional rules.
Dissenting / Concurring Opinion Summary
No dissenting or concurring judgments were delivered; the order and reasoning reflect the views of the single presiding judge.
Procedural Innovations
- The Court imposed a strict two-month timeline for authorities to finalise the seniority list and complete consequential promotions.
- Mandated that authorities must provide reasonable opportunity to all stakeholders to file objections to the proposed final seniority list.
- Clarified the non-applicability of subsequently framed central rules (NMC) to institutional promotion exercises proceeding under pre-existing statutory rules.
Alert Indicators
- ✔ Precedent Followed – The judgment affirms and applies long-standing principles of administrative law relating to mandatory compliance with statutory rules and judicial power to ensure non-arbitrary service matters.
- 📅 Time-Sensitive – The judgment imposes strict timeframes for compliance, and addresses delay as a core procedural grievance.