- Seniority of civil servant will be determined from the date of actual appointment. [Anti-dated and proforma appointments are not regular appointments rather fall within the domain of residuary powers of the government under Section 22 of the Civil Servants Act]. Syed Subtain H. Kazmi, Tehsildar presently posted at Bagh Development Authority v. Syed Mumtaz H. Kazmi, Naib Tehsildar presently posted at office of Dy. Comm., Bagh, Haveli 2013 SCR 889 (G)