The Allahabad High Court has ruled that simply securing the marks required for a higher post does not guarantee an SBI officer placement in that post. The court said SBI can assess an officer’s merit and suitability for future leadership responsibilities before giving placement in the MMGS-II grade.
The court also upheld SBI’s decision to limit MMGS-II placement to the top 10% of officers in a batch based on merit. It said this limit did not take away any existing right of trainee or probationary officers and instead made the selection process more objective.
Court Allows SBI’s Appeal
A division bench of Justices Saumitra Dayal Singh and Swarupama Chaturvedi delivered the judgment on August 21. The bench allowed SBI’s appeal against a November 2024 order passed by a single judge.
The single judge had earlier declared SBI’s December 16, 2020 Training and Confirmation Policy invalid for the 2019 batch and had directed the bank to place the affected officers in MMGS-II under the earlier policy, along with notional benefits.
Dispute Over 2019 Batch
The case involved SBI Trainee Officers from the 2019 batch. These officers had earlier worked as Assistants and were appointed as Trainee Officers after clearing an all-India examination.
Their appointment letters stated that their service would be governed by the SBI Officers’ Service Rules, 1992. Their confirmation after training was to be done according to the policy applicable at the time.
Earlier Policy Had a 75% Threshold
Under SBI’s April 23, 2019 policy, officers were continuously assessed during their training. Officers who scored at least 50% in the overall assessment, or 45% in the case of SC/ST and PwD candidates, were to be confirmed in the Junior Management Grade Scale-I (JMGS-I). Those who scored 75% or more, or 70% for SC/ST candidates, were to be considered for placement in Middle Management Grade Scale-II (MMGS-II).
Officers Claimed Higher Grade
The officers who approached the court argued that they had scored more than the required 75% marks. They claimed that they were therefore entitled to MMGS-II placement under the policy that was in force when they were appointed. However, the division bench rejected this argument.
Confirmation and Higher Grade Are Different
The court made a clear distinction between confirmation in service and placement in MMGS-II. According to the SBI Officers’ Service Rules, an officer can be confirmed after successfully completing training. However, placement in MMGS-II is a separate matter and depends on the officer’s merit and suitability for future leadership responsibilities. The court said that confirmation does not automatically give an officer a right to the higher grade.
75% Marks Only Made Officers Eligible
The court also examined the wording of the 2019 policy. It noted that officers meeting the lower marks requirement “shall be confirmed”, while those reaching the 75% threshold “shall be considered” for MMGS-II placement.
The bench said these two expressions have different meanings. Therefore, achieving the minimum marks only made an officer eligible for consideration for MMGS-II and did not guarantee placement. The court concluded that minimum merit during training alone was not enough to claim placement in MMGS-II.
Why SBI Introduced the Top 10% Rule
The court also looked at the experience of previous batches. In the 2017 batch, 807 out of 816 Trainee Officers and 1,445 out of 1,592 Probationary Officers were placed in MMGS-II. In the 2018 batch, 1,497 out of 1,524 Trainee Officers received placement in the grade. These placements were made mainly on the basis of the minimum marks requirement under the earlier policy.
SBI later received feedback that many officers placed in MMGS-II did not have enough experience and maturity for middle-management responsibilities. Some officers had limited experience handling important branch-level responsibilities and found it difficult to manage their new roles.
The bank considered removing MMGS-II placement completely or introducing a limit. It ultimately decided to limit placement to the top 10% to maintain competition and select officers with the highest assessment scores.
New Policy Applied to 2019 Batch
Under the December 16, 2020 policy, the top 10% of Probationary Officers and Trainee Officers based on assessment scores could be considered for MMGS-II, subject to other requirements. The selection was to be made on an all-India basis instead of separately for different circles. The High Court found this system to be objective and transparent for assessing an officer’s suitability for future leadership roles.
Court Says Policy Was Not Retrospective
The officers also argued that SBI had changed the rules after they were appointed and that applying the new policy to the 2019 batch was retrospective.
The court rejected this argument.
It noted that the 2018 batch had already completed its training and assessment before the new policy came into force. However, the 2019 batch was still undergoing assessment when the new policy was introduced. The assessment for the 2019 batch ended on March 17, 2021, while confirmation was due on June 16, 2021. Therefore, the court found that the new policy could be applied to the 2019 batch.
High Court Upholds SBI Decision
The court held that the new policy did not affect the officers’ selection or their right to confirmation in JMGS-I. The 75% marks requirement continued to decide who could be considered for MMGS-II. The change was that SBI could select the highest-ranking 10% from among the eligible officers based on merit.
The High Court therefore held that the policy was consistent with SBI’s service rules, was not retrospective and did not unfairly discriminate against the 2019 batch. The court allowed SBI’s appeal, dismissed the officers’ writ petition and made no order regarding costs.
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