A mere pendency of a disciplinary proceeding or a case in a Criminal Court is not a bar to give promotion subject to final resulting the disciplinary proceeding or the criminal case. It is not known as to when the criminal case will be disposed of. A govt. servant cannot be asked to wait for an indefinite period to get promotion. Further the provision for promotion increases efficiency of the public service while stagnation reduces efficiency and makes the service ineffective. The promotion is a condition of service and no officer should be deprived of promotion and superseded without justifiable reasons. It is a matter of moment and cannot be treated as causal or a routine affair.
