1. It is indeed correct that it is within the discretion of the competent authority to award a proforma promotion to any civil servant provided it is just an equitable and does not adversely affect the rights of another civil servant — This rule is however of not universal application — It differs from case to case. Nazar Ahmed Khan  v. Sabir Hussain Naqvi and 3 others 2000 SCR 580 (B)
  2. Promotion made without the approval of relavant Selection Board was illegal and void in the eye of law. Nazar Ahmed Khan  v. Sabir Hussain Naqvi and 3 others 2000 SCR 580 (C)
  3. Uptil 1992 the post of Circle Registrar was not available as such the ant-date promotion of appellant could not have been awarded from 1985 — Seniority (of appellant) would commence from the date of his promotion i.e.16.7.1992. Nazar Ahmed Khan  v. Sabir H. Naqvi 2000 SCR 580 (D)
  4. If it is shown that the appellant was not promoted in 1991 when his batch-mates were promoted without there being any fault on his part, he can claim pro forma promotion irrespective of the fact whether he was holding the post of Deputy Secretary on acting charge basis or not — Promotion order of the appellant was amended giving retrospective effect. Sabir Hussain Khan Abbasi v. Azad Govt. and another 2002 SCR 62 (B)
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