The Supreme Court has held that courts cannot substitute the assessment methodology adopted by expert promotion committees by introducing their own formula for evaluating candidates. There is no legal basis for averaging Annual Performance Reports (APR/PMS) scores with Work Report marks to determine eligibility for promotion under the Council of Scientific and Industrial Research (CSIR) Scientists Recruitment and Promotion Rules.
The Bench of Justice Manoj Misra and Justice Manmohan allowed appeals filed by the Director General, CSIR, setting aside the judgments of the Central Administrative Tribunal (CAT) and the Karnataka High Court, both of which had directed reconsideration of a scientist’s promotion based on an averaged scoring method.
The respondent, a CSIR scientist, claimed that he became eligible for promotion to the post of Senior Scientist much earlier than the date on which he was actually promoted. He argued that during the relevant residency period, his Annual Performance Reports (APRs)/Performance Mapping Scheme (PMS) scores consistently exceeded the prescribed threshold, averaging approximately 92.1%, thereby qualifying him for consideration by the Assessment Committee.
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However, when the Assessment Committee evaluated his candidature, it awarded 82% after assessing his Work Report, which fell below the 85% benchmark required for promotion. Consequently, the committee declared him “Not Yet Fit for Promotion.”
The scientist challenged the decision before the CAT, contending that the Assessment Committee should have averaged his APR/PMS score (92.1%) with the Work Report score (82%), resulting in a combined score above the qualifying threshold.
The CAT accepted the scientist’s argument and held that the average of the two scores exceeded the prescribed benchmark, making him eligible for promotion. It directed CSIR to grant him promotion with retrospective effect.
The Karnataka High Court substantially agreed with the Tribunal’s interpretation but modified the relief by directing CSIR to convene a Review Departmental Promotion Committee instead of granting direct promotion.
Reversing both decisions, the Supreme Court held that neither the CSIR Recruitment Rules nor the 2011 amendment mandated averaging of APR/PMS marks and Work Report scores.
The Court observed that the promotion process under the CSIR Rules operates in two distinct stages:
- Stage One: The Internal Screening Committee examines APR/PMS scores to determine whether a scientist satisfies the prescribed eligibility threshold for further assessment.
- Stage Two: The Assessment Committee evaluates eligible candidates by considering the Work Report along with relevant performance records and independently determines whether the candidate is “Fit for Promotion” or “Not Yet Fit for Promotion.”
The Court emphasized that the Assessment Committee is composed of domain experts and possesses discretion to evaluate scientific work and determine suitability.
A central issue before the Court was the interpretation of Paragraph 3(b) of the CSIR Circular dated June 1, 2011, which states that assessment shall be based on both APR/PMS and the Work Report.
The Supreme Court clarified that the provision merely requires the Assessment Committee to consider both inputs. It does not prescribe any mathematical formula or averaging mechanism for arriving at the final score.
According to the Court, the CAT and High Court effectively rewrote the Rules by introducing a method that the rule-making authority had never provided.
The Bench observed that courts ordinarily cannot read additional words into statutory provisions unless such an interpretation is absolutely necessary to give effect to legislative intent, which was not the case here.
The Court stressed that evaluation of scientists involves specialised technical assessment which should ordinarily remain within the domain of expert committees.
It noted that the importance of a scientist’s Work Report may vary depending on the complexity and nature of research undertaken, making it inappropriate for courts to impose rigid scoring formulas.
The judgment further observed that, in the absence of any statutory provision prescribing weightage or averaging of marks, the Assessment Committee must retain discretion in assessing overall suitability for promotion.
The Bench also noted that the respondent had not alleged mala fides against any member of the Assessment Committee. Moreover, the scientist was subsequently found fit and promoted in a later assessment, indicating that the committee had objectively evaluated his candidature rather than acting arbitrarily.
Allowing the appeals, the Supreme Court set aside the judgments of the Karnataka High Court and the Central Administrative Tribunal.
The court held that the averaging of APR/PMS scores and Work Report marks is not contemplated under the CSIR Recruitment Rules or the 2011 Circular.
The court upheld the discretion of the Assessment Committee in determining a candidate’s suitability for promotion and dismissed the Original Application filed by the respondent scientist.
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