3 min readChandigarhApr 18, 2026 11:38 AM IST
First published on: Apr 18, 2026 at 11:38 AM IST
The Chandigarh Bench of the Central Administrative Tribunal (CAT) has dismissed a bunch of applications filed by Chandigarh Police constables challenging the requirement of the qualifying B-1 test for promotions to the post of Head Constable (HC).
Pronouncing the order on April 2, the tribunal held that “the impugned circulars, notification and Standing Orders are in consonance with the statutory provisions and fall within the permissible domain of executive policy. No case for judicial interference is made out”.
Applicants Pardeep Kumar and others, through their counsel, had challenged notifications and circulars mandating willingness for the B-1 test under the 25 per cent quota, arguing “promotions have historically been granted based on seniority-cum-merit and the sudden insistence on a test is arbitrary and discriminatory”.
They said forcing senior constables to compete with juniors after years of service “lacked justification and violated equality principles”.
Senior counsel for the UT Administration Arvind Moudgil opposed the pleas, submitting that the promotion process is governed by Rule 13.7 of the Punjab Police Rules, which is a structured mechanism, including seniority-cum-merit, 25 per cent quota through B-1 test and 5 per cent sports quota.
Moudgil argued that the B-1 test is an integral statutory requirement aimed at ensuring efficiency and merit in the police force and cannot be dispensed with. “Earlier relaxations were only one-time measures, and do not create any enforceable right. The impugned notifications and circulars were issued within the competence of the administration and strictly in accordance with the rules,” Moudgil further submitted.
The tribunal, on hearing the arguments, rejected the contentions of applicants’ counsel, observing that “no employee can claim right to promotion contrary to the scheme of Rules”.
It further held that the requirement of appearing in a written test “does not violate Articles 14 or 16, particularly when it is uniformly applied and has a rational nexus with the objective of ensuring efficiency and merit in promotions within a disciplined force like the police.”
The bench also noted that the B-1 test mechanism had not been abandoned and continued to be part of the statutory framework. “Temporary deviations or relaxations do not render a statutory provision obsolete or unenforceable,” it said.
On the issue of past practice, the tribunal observed that earlier relaxations granted in certain years were only one-time measures and could not be treated as a precedent or enforceable right.
The tribunal further recorded that during the pendency of the case, the applicants themselves referred to a draft amendment circulated by the administration, indicating that such matters fall within the domain of policy and administrative decision-making.
Earlier, the tribunal had declined to grant interim relief, stating that no prima facie case was made out and allowing the B-1 test process to continue.
“In the absence of any violation of statutory provisions or constitutional mandate, the Tribunal ought not to interfere in policy matters,” the order said.
Accordingly, all original applications were dismissed, with the tribunal leaving it open for the competent authority to consider any request for relaxation in accordance with the law.
The CAT Chandigarh Bench has upheld the mandatory B-1 test for promotions to Head Constable, dismissing a plea by constables who claimed the merit-based exam was "arbitrary" compared to traditional seniority rules. (Representative image) 
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