Summary: Summary pending.

Summary: (a) Service Law ----Adverse remarks—Promotion—Supersession—Effect of expunged adverse remarks on subsequent DPC decisions—Held: Once adverse remarks recorded in the respondent’s Annual Confidential Report were judicially set aside by the Federal Service Tribunal and the judgment attained finality up to the Supreme Court, such remarks stood obliterated from the service record ab initio. Any supersession based solely on those remarks automatically lost legal effect. Administrative orders resting on a foundation that has ceased to exist cannot survive. Non-challenge to individual DPC supersession orders, being derivative in nature, is of no consequence; law does not require a futile challenge to orders whose substratum has already been judicially extinguished. (b) Service Law ----Limitation—Condonation of delay—Tribunal’s discretion—Departmental representation filed after limitation period—Held: The Federal Service Tribunal recorded sufficient cause and exercised discretion judiciously in condoning the delay considering factual circumstances including security and access constraints of the respondent’s posting—No jurisdictional or legal error shown; interference by the Supreme Court unwarranted. (c) Promotion—Ante-dated or pro-forma promotion—Entitlement—Where adverse remarks forming the sole basis of supersession are subsequently expunged, the officer’s right to promotion relates back to the date he first became eligible—The respondent, having been wrongly superseded on a ground later declared void, was rightly granted promotion from 2015, when his entitlement first matured. (d) Case Distinction— Abdul Ghani Chaudhry v. Secretary Establishment (1998 SCMR 2544) distinguished; that case did not involve the setting aside of adverse remarks forming the foundation of supersession, hence its ratio inapplicable to the present facts. Cited Cases: • Abdul Ghani Chaudhry v. Secretary Establishment, Islamabad & others, 1998 SCMR 2544 (distinguished) Disposition: Leave to appeal declined—Petition dismissed—Federal Service Tribunal judgment dated 02.11.2022 upheld; respondent entitled to promotion retrospectively from 27.07.2015.

Summary: (a) Service law — Promotion — Amendment of rules — Prospective versus retrospective effect — Sub Engineers (BPS-16) — Khyber Pakhtunkhwa C&W Department — Respondents became eligible for promotion to Assistant Engineer (BPS-17) under the then-existing rules, but the Department deferred DPC meetings pending proposed amendments; new rules notified later (20-01-2023) rendered them ineligible — Held, that civil servants who had fulfilled eligibility criteria under the prevailing rules acquired a legitimate expectation to be considered for promotion under those rules; departmental delay cannot defeat such expectation. Amendments affecting seniority or eligibility operate prospectively unless the parent statute expressly authorizes retrospective effect — no such authority existed here. (b) Administrative law — Legitimate expectation and fairness — Once promotion cases were ripe for DPC consideration, withholding them to await rule amendments amounted to arbitrary exercise of discretion, contrary to settled principles of fairness and good governance — Departmental Promotion Committee has no power to postpone meetings or apply amendments retrospectively to deprive officers of accrued rights. (c) Interpretation of rules — Presumption against retrospectivity — Promotion and seniority rules ordinarily regulate future service conditions; they cannot retrospectively curtail an accrued right or expectation unless explicit legislative mandate to that effect exists. (d) Constitutional guarantees — Arts. 4, 9 & 25 — Retrospective deprivation of accrued promotional rights without lawful authority offends due process, equality and protection of law. (e) Disposition — Petitions dismissed; Service Tribunal’s consolidated judgment dated 25-07-2024 upheld; respondents entitled to promotion to Assistant Engineer (BPS-17) in accordance with rules applicable when they became eligible.

Summary: (a) Punjab Civil Servants Act (VIII of 1974), S. 23—Punjab Provincial Management Service Rules, 2004—Rule-making power—Amendment through notification—Status and enforceability— Governor Punjab lawfully amended Schedule-I to the PMS Rules, 2004 via notification dated 21.08.2019, waiving the condition of five years' service as Tehsildar for promotee officers seeking promotion to PMS (BS-17). Held, rules framed under statutory power under S. 23 have the force of law and remain binding unless declared ultra vires by a competent court or withdrawn by the Governor. Departmental views or tribunal directions do not nullify the operation of such validly enacted rules. Case cited: Ahmad Hassaan v. Govt. of Punjab 2005 SCMR 186 (b) Service law—Promotion—Discrimination—Validity of amendment relaxing criteria for specific class—Legitimate expectations— Petitioners, promotee Tehsildars, were considered for promotion to PMS (BS-17) under amended rules. Inducted Tehsildars objected, alleging discrimination, since amendment removed five-year condition only for promotees. Held, notification was validly issued before induction of respondents; they joined service with knowledge of existing promotion criteria. Promotion process could not be halted in anticipation of rule amendments or pending litigation unless existing notification is struck down or revised. (c) Constitutional petition—Maintainability—Service Tribunal—Challenge to promotion process without challenging underlying rules— Respondents' appeal before Punjab Service Tribunal did not question vires of the 21.08.2019 notification. Tribunal exceeded jurisdiction by suspending promotion process despite not having authority to examine constitutionality of statutory rules. Held, tribunal ought to have awaited outcome of constitutional challenge before High Court; process cannot be stayed indefinitely in absence of legal basis. (d) Administrative law—Departmental Promotion Committee (DPC)—Jurisdiction—Effect of pending rule amendments— Held, DPC is not empowered to question legality of service rules nor defer promotions on pretext of contemplated amendments. Rules in force must be implemented; promotions cannot be withheld merely because revision is under consideration. Case cited: • Govt. of Khyber Pakhtunkhwa v. Hizbullah Khan 2021 SCMR 1281 • Aatika Hina Mushtaq v. Secretary, Special Education (CPLA No. 3116/2022, judgment dated 21.04.2025) (e) Civil service—Filling of vacant posts—Administrative obligation—Delay—Effect— Over 110 vacant PMS posts could not remain unfilled due to inter-party dispute. Held, public employment is an essential state function; sanctioned posts reflect deliberate institutional need and must be filled promptly unless abolished. Prolonged vacancy undermines public confidence, administrative efficiency, and constitutional guarantees of equal opportunity in public employment. Disposition: Leave granted. Appeal allowed. Promotion process of Tehsildars as PMS Officers to proceed under 2004 Rules as amended by notification dated 21.08.2019, unless duly withdrawn or further amended by the Governor.

Summary: (a) Constitution of Pakistan, 1973 ---- Arts. 4, 9, 10A, 18 & 25 --- Civil Servants Act, 1973 --- Fundamental Rule 17 --- Promotion to BPS-22 --- Supersession without reasons --- Denial of fair consideration --- Proforma promotion --- Doctrine of legitimate expectation --- Remand to High-Powered Selection Board. Petitioner, a BS-21 officer of the Police Service of Pakistan, challenged his repeated supersession for promotion to BS-22 without being afforded any reasons or fair opportunity. Despite having an unblemished service record with outstanding Performance Evaluation Reports (PERs) from 2013 to 2018 and being senior to others who were promoted, the petitioner was overlooked by the High-Powered Selection Board (HPSB) in multiple meetings. No adverse material was found in the official record, yet the HPSB minutes included negative remarks not grounded in any documented performance review. The Supreme Court held that while promotion is not a vested right, the right to fair and lawful consideration for promotion is enforceable. Where a civil servant attains the age of superannuation without being justly considered for promotion, the case must be assessed under the framework of proforma promotion as envisaged in Fundamental Rule 17. The Court observed that delay or omission in considering eligible officers due to administrative lapses entitles them to proforma promotion with consequential benefits. The High Court’s dismissal was found to have overlooked the factual record and was influenced by unverified notings in HPSB proceedings. The judgment was set aside and the matter remanded to the HPSB to re-evaluate the petitioner’s case for proforma promotion in a fair, impartial, and timely manner, with specific instructions for decision within two months. Cited Cases: • Federation of Pakistan v. Jahanzeb 2022 SCMR 2020 • Alam Chand v. Jamil Ahmad 2008 SCMR 980 • Abid Hussain Sherazi v. Secretary, M/O Industries & Production 2005 SCMR 1742 • Secretary Health Department, Punjab v. Dr. Abida Iqbal 2009 SCMR 61 • Federal Public Service Commission v. Shiraz Manzoor 2023 SCMR 2087 ----Disposition: Appeal allowed; High Court judgment set aside; matter remanded to HPSB for fresh consideration within two months.

Summary: (Against the judgment dated 31.03.2002 passed by the Federal Service Tribunal, Islamabad in Appeal No. 1250(P)CS of 2018). (a) Khyber Pakhtunkhwa Service Tribunals Act (I of 1974)--- ----S.4---Promotion---Vacant post---Current charge---Administrative neglects---Civil servant was aggrieved of being assigned the post on current charge basis instead of being promoted n the said post being a vacant post---Validity---When the post in question fell vacant, the civil servant was the senior-most eligible officer at that time, who was entitled to be considered for promotion with effect from that date---Delay caused by authorities in convening DPC or in processing petitioner's case due to procedural irregularities such as issues with the author of his PERs could not be used to defeat his rightful claim---Competent authority was under a duty to act with a fine sense of judgment, which it had failed to do---The moment the post became vacant and civil servant met required qualifications, legitimate expectation arose in his favour that he would be considered for promotion in a fair and timely manner---Failure to fulfil such expectation, without lawful justification, amounted to arbitrariness and procedural unfairness---Such delay in promotion of civil servant stemmed not from personal shortcoming but from systemic inefficiencies and administrative neglect---Civil servant must not bear the consequences of internal procedural lapses---Supreme Court directed the authorities to promote the civil servant to post in question with effect from the date on which vacancy in his quota first became available---Supreme Court also directed the authorities that all consequential benefits, including seniority, arrears of pay and service entitlements would follow from backdated promotion---Supreme Court set aside judgment passed by Service Tribunal---Appeal was allowed. Secretary, Government of Punjab v. Khalid Hussain Hamdani 2013 SCMR 817; Brean v. Amalgamated Engineering Union (1971) 2 QB 175; Messrs Gadoon Textil Mills v. WAPDA 1997 SCMR 641; Province of Sindh v. Ghulam Shabbir 2023 SCMR 686; Government of Khyber Pakhtunkhwa v. Fazli Ghufran 2022 SCMR 1765; Dr. Yasmeen Zafar v. Dr. Shehla Sami 2019 SCMR 993; Khalid Mehmood v. Chief Secretary, Punjab 2013 SCMR 544; WAPDA v. Haji Abdul Aziz 2012 SCMR 965; Muhammad Siddique v. Director, Special Education 1998 SCMR 88; Narender Chadha v. Union of India AIR 1986 SC 638; A. Janardhana v. Union of India AIR 1983 SC 769; B.S Yadav v. State of Haryana AIR 1981 SC 561; Dr. Muhammad Amjad v. Dr. Israr Ahmed 2010 SCMR 1466; WAPDA v. Muhammad Nawaz Khan 1998 SCMR 640; S. Abu Saeed v. Government of N.W.F.P. 1990 SCMR 1623; Government of N.W.F.P. v. Buner Khan 1985 SCMR 1158; Federation of Pakistan v. Jahanzeb 2023 PLC (C.S.) 336; NADRA v. Jawad Khan 2023 SCMR 1381 and Bashir Ahmed Badini v. Hon'ble Chairman and Member of Administration Committee 2022 SCMR 448 rel. (b) Civil service--- ----Vacant post, filling of---Principle---Every sanctioned post within a government department or public institution exists to serve a defined functional need and must be filled promptly upon falling vacant---So long as the post continues to exist and has not been formally abolished or frozen pursuant to a lawful policy decision, such as due to budgetary constraints or other demonstrable administrative exigencies, it must be filled within a reasonable time---Unjustified delays in such regard not only disrupt efficient functioning of the institution but also weaken its service delivery capacity---Vacancies, when left unattended, often lead to informal arrangements and ad hoc delegations of authority that foster opacity, enable nepotism and corrode principles of merit and transparency. Ms. Shireen Imran, Advocate Supreme Court for Petitioner. Raja Muhammad Shafqat Abbasi, DAG, Riaz Hussain Azam, Advocate-on-Record along with Javed Iqbal, Additional Secretary, Finance and Fiaz Afridi, DAG, CGA Office and Abdullah A.A.O. for Respondents. Assisted by: Umer A. Ranjha, Judicial Law Clerk, Supreme Court of Pakistan. Date of hearing: 19th May, 2025.

Summary: (a) Constitution of Pakistan—Arts. 4 & 25—Civil Servants Act, 1973—Promotion—Entitlement to backdated promotion—Principles of fairness, non-discrimination, and legitimate expectation—Performance Evaluation Reports (PERs)—Effect of non-adverse remarks— Where a civil servant is eligible, senior-most, and performing duties of a higher post on current charge basis, denial of promotion solely on the basis of non-adverse or suggestive comments in Performance Evaluation Reports (PERs) constitutes an arbitrary exercise of discretion. In the present case, the petitioner was eligible for promotion to BS-17 as Private Secretary from 06.08.2015 but was promoted belatedly in 2018. The remarks in his PERs (e.g., “needs to improve discipline and manners”) were held to be non-adverse and could not legally justify withholding promotion. Further, the PERs were not authored by the competent authority, raising procedural concerns. The delay in promotion due to internal mismanagement violated the petitioner’s legitimate expectation and right to fair treatment under Articles 4 and 25 of the Constitution. Cited Cases: Secretary, Govt. of Punjab v. Khalid Hussain Hamdani (2013 SCMR 817) Messrs Gadoon Textile Mills v. WAPDA (1997 SCMR 641) Federation of Pakistan v. Jahanzeb (2023 PLC (C.S.) 336) Province of Sindh v. Ghulam Shabbir (2023 SCMR 686) Govt. of KPK v. Fazli Ghufran (2022 SCMR 1765) Khalid Mehmood v. Chief Secretary Punjab (2013 SCMR 544) (b) Civil service—Departmental Promotion Committee (DPC)—Discretionary powers—Requirement to act reasonably and with objectivity—Improper deferral of promotion—Effect— The DPC’s repeated deferral of the petitioner’s promotion without affording an opportunity of hearing or rectification of alleged deficiencies violated principles of natural justice. The Supreme Court reiterated that discretion in promotion matters must be exercised in a structured, objective, and lawful manner—unguided discretion opens the door to favouritism, procedural unfairness, and administrative injustice. Mere procedural irregularities, such as the non-signing of PERs by the designated authority, cannot be used to delay or deny promotion. (c) Service law—Promotion with retrospective effect—Entitlement from date of vacancy—Administrative delay—Legitimate expectation— When a post becomes vacant and an eligible civil servant is available, he or she has a legitimate expectation to be considered fairly and promptly. The Supreme Court reaffirmed that promotions must be considered from the date a vacancy in the officer’s quota arises, and internal inefficiencies or lapses cannot defeat this right. Delay in convening DPC or flawed administrative processing cannot justify loss of seniority or arrears. Cited Cases: Dr. Muhammad Amjad v. Dr. Israr Ahmed (2010 SCMR 1466) WAPDA v. Muhammad Nawaz Khan (1998 SCMR 640) Dr. Yasmeen Zafar v. Dr. Shehla Sami (2019 SCMR 993) Narender Chadha v. Union of India (AIR 1986 SC 638) (d) Public administration—Sanctioned posts—Duty to fill vacancies promptly—Effect of delay— Every sanctioned post exists to serve a functional purpose and must be filled within a reasonable time. Unfilled vacancies cause inefficiency, encourage informal delegation of authority, and erode transparency. The Supreme Court stressed that public institutions are public trusts, and government officers are trustees of public duty, who must not delay filling vacancies absent cogent and lawful justification. Disposition: Appeal allowed. Impugned judgment of the Federal Service Tribunal set aside. Petitioner directed to be promoted to BS-17 with effect from 06.08.2015 (date of vacancy). All consequential benefits including seniority, arrears of pay, and revised pay fixation to follow. Compliance report to be submitted within 30 days.

Summary: (a) Service Law – Proforma Promotion – Principles and Entitlement---Punjab Civil Servants (Appointment & Conditions of Service) Rules, 1974, R. 13(i)---Punjab Subordinate Judiciary---Proforma promotion---Right of consideration---Appellant was terminated in 2004 but later reinstated in service in 2014 with back benefits and continuity of service---His junior was promoted as Senior Civil Judge in 2013, whereas he was promoted in 2019 after clearance of adverse reports---Held, once all impediments to promotion had been removed and appellant was deemed continuously in service, he was entitled to consideration for promotion from the date his junior was promoted---Failure to grant such relief would amount to unfair treatment and denial of legitimate career progression---Reliance placed on Abdul Jabbar Khan v. Government of Sindh (1996 SCMR 850), Chief Secretary, Sindh v. Riaz Ahmed Massan (2016 SCMR 1784), and Nazir Ahmed Langah v. Lahore High Court, Lahore (2024 PLC (C.S.) 1566).(b) Administrative Law – Officiating Promotion – Effect on Proforma Promotion---Officiating promotion v. regular promotion---Whether officiating promotion precludes a civil servant from claiming proforma promotion---Held, an officiating promotion, if made in accordance with eligibility criteria and not rescinded later, does not permanently preclude a civil servant from receiving proforma promotion if his junior was promoted to a substantive post---Respondents failed to show that the junior’s promotion was not made against a regular vacancy, thus the appellant’s claim was valid---Reliance placed on Secretary to Government of Punjab, Communication and Works Department v. Muhammad Khalid Usmani [2017 PLC (C.S.) 373].(c) Service Law – Limitation – Joinder of Necessary Parties---Limitation Act, 1908, S. 22---Whether an appeal is barred due to impleading necessary parties at a later stage---Held, if an appeal is filed in time against the primary department, subsequent joinder of necessary parties does not render the entire appeal time-barred---Where administrative inefficiency or procedural delays cause a civil servant to be deprived of his rightful claim, he cannot be non-suited merely due to a technical procedural lapse---Reliance placed on Messrs Khurshid Soap and Chemical Industries (Pvt.) Ltd. v. Federation of Pakistan (PLD 2020 SC 641) and Chami Narayanan v. V.R. Krishna Iyer (AIR 1998 Kerala 365).(d) Administrative Justice – Doctrine of Bona Fide Mistake – Effect on Procedural Compliance---Principle Actus non facit reum nisi mens sit rea (an act alone does not make one liable unless there is wrongful intent)---Bona fide mistakes in procedural matters such as misjoinder or non-joinder of parties should not hinder substantive justice---Held, where an appellant makes a genuine procedural mistake without mala fide intent, courts should prioritize substantive justice over technicalities---Reliance placed on Pitt v. Holt [(2013) UKSC 26], Barclays Bank Ltd v. W J Simms, Son and Cooke (Southern) Ltd [(1980) QB 677], and Guruvayya v. Dattatraya [(1903) ILR 28 Bom. 11].(e) Fundamental Rights – Fair Treatment in Service Matters---Right to equal opportunity in service progression---Failure to consider a civil servant for proforma promotion despite removal of adverse remarks constitutes denial of fair treatment and violates principles of equality and justice---Reliance placed on Federation of Pakistan v. Jahanzeb [2023 PLC (C.S.) 336] and Wadhu Mal v. Province of Sindh [2023 PLC (C.S.) 1310].--- Disposition:Appeal allowed – Impugned orders dated 15.11.2021 and 18.12.2021 set aside.Respondent authority directed to reconsider the appellant’s proforma promotion from the date his junior was promoted, in accordance with law.

Summary: A BPS-20 Office is aggrieved his nomination has been superseded by CSB. (a) Constitutional Law — Maintainability of Writ Petition — Bar of Jurisdiction under Article 212 of the Constitution: The bar under Section 4 of the Federal Services Tribunal Act, 1973, does not apply where the dispute pertains to the fitness of a civil servant for promotion, rather than the terms and conditions of service. A civil servant has a fundamental right to fair consideration for promotion, which is distinct from the right to promotion itself. Consequently, the constitutional jurisdiction of the High Court under Article 199 is not ousted in such cases. (Orya Maqbool Jan v. Federation of Pakistan, 2014 SCMR 817; Secretary Establishment Division v. Aftab Ahmed Maneka, 2015 SCMR 1006 applied). (b) Right to Fair Consideration for Promotion — Due Process and Article 10A of the Constitution: A civil servant has the right to be considered for promotion in a fair and just manner, which includes the right to confront and rebut any adverse material used against him. Consideration of intelligence agency reports at the CSB meeting without prior notice to the officer and without affording an opportunity to contest the allegations violates the principles of due process and fair trial under Article 10A of the Constitution. (I.A. Sherwani v. Government of Pakistan, 1991 SCMR 1041; Tariq Aziz-ud-Din case, 2010 SCMR 1301 followed). (c) Central Selection Board (CSB) — Role in Promotion — Application of Arbitrary Discretion: Under Rule 18(3)(b) of the Civil Servants Promotion Rules, 2019 (CSPR), only 30 marks are allocated to the CSB’s collective judgment, while the remaining 70 marks are based on quantified performance evaluations (PERs and TERs). The CSB exceeded its authority by disregarding the quantification criteria and awarding disproportionate deductions based solely on intelligence reports. The CSB's decision violated the structured framework of the CSPR and constituted an arbitrary exercise of discretion. (Muhammad Zafeer Abbasi v. Government of Pakistan, 2003 PLC (CS) 503 applied). (d) Intelligence Reports in Promotion Decisions — Legality and Evidentiary Value: The use of intelligence reports that are not commissioned under applicable rules, lack verifiable evidence, and are not disclosed to the officer prior to the CSB meeting renders them legally infirm and ultra vires the fundamental rights to due process and information under the Constitution. The introduction of intelligence reports at the final stage of promotion consideration, without prior confrontation or verification, amounts to a denial of natural justice. (PIA v. Nasir Jamal Malik, 2001 SCMR 934; Abdul Hafeez Abbasi v. PIHC, 2002 SCMR 1034 followed). (e) Amendment to the Civil Servants Promotion Rules, 2019 — Validity and Scope of Rule 2(p) and Rule 4(5): The 2022 amendment to the CSPR introduced Rule 2(p) (defining Special Vetting Agency (SVA)) and Rule 4(5) (allowing CSB to consider intelligence reports of SVAs). However, these rules fail to specify the weightage of intelligence reports in the overall promotion criteria and do not provide procedural safeguards for officers to contest such reports. The vagueness of these rules exposes both the CSB and civil servants to arbitrary decisions, lack of transparency, and potential abuse. (f) Confidentiality of Intelligence Reports — Conflict with Fundamental Rights: There is no legal provision in the CSPR that grants confidentiality to intelligence reports used in promotion decisions. Any attempt to keep such reports secret violates the fundamental rights to information (Article 19A) and due process (Article 10A) of the Constitution. Information that adversely affects a person’s career cannot be classified as confidential without affording the affected individual an opportunity to contest it. (g) Failure to Provide a Transparent Promotion Process — Impact on Bureaucracy and Governance: The unfettered reliance on unverifiable intelligence reports in civil servant promotions creates a chilling effect, making officers susceptible to external pressures, political influence, and coercion by intelligence agencies. The lack of procedural safeguards for officers to defend against adverse reports undermines bureaucratic independence and good governance. (Managing Director (Power), WAPDA v. Muhammad Luqman, PLD 2003 SC 175 applied). (h) Remedy and Directions to the Central Selection Board (CSB): The CSB’s decision dated 01.08.2023 superseding the petitioner was set aside, and the immediately next CSB meeting was directed to reconsider the petitioner’s promotion to BPS-21 strictly in accordance with the marking and ranking criteria stipulated in CSPR, without reliance on the intelligence reports that were neither disclosed nor substantiated. -----Disposition: Writ Petition Allowed — Impugned CSB Decision dated 01.08.2023 Set Aside — Petitioner’s Case to be Reconsidered in the Next CSB Meeting in Accordance with CSPR, Excluding Intelligence Reports Not Previously Disclosed or Substantiated.

Summary: (a) Constitution of Pakistan ----Art. 10A & Art. 199---Promotion of civil servant---Denial of due process---Consideration of intelligence reports without opportunity of rebuttal---Petitioner, a BS-20 officer of the Information Group, was superseded by the Central Selection Board (CSB) on the basis of intelligence reports alleging questionable integrity, despite having an outstanding service record and strong recommendations from his Secretary---Court held that reliance on undisclosed, unverified, and untested intelligence reports without confronting the petitioner violated the fundamental right to due process under Art. 10A of the Constitution---Promotion decisions must be based on tangible, credible material subject to rebuttal by the affected officer---Such reports, when not lawfully commissioned or procedurally vetted, cannot override a consistent professional service record. (b) Civil Servants Promotion (BPS-18 to BPS-21) Rules, 2019 (CSPR) ----Rr. 2(p), 4(5), 18(3)(b), 18(3)(d) & Schedule IV---Intelligence reports---Marking criteria---Scope---Court observed that the 2022 amendment introducing Special Vetting Agencies (SVAs) and authorizing the CSB to consider intelligence reports lacked clear procedural safeguards and failed to define weightage in the scoring scheme under CSPR---The CSB’s award of only 10 out of 30 discretionary marks under “collective judgment” was not explained in light of Schedule IV, which allows a maximum deduction of 3 marks for integrity concerns---Such arbitrary deductions, without evidentiary basis or procedural opportunity to rebut, render the evaluation flawed and unlawful. **(c) Service Law---Promotion---Right to fair consideration---Maintainability of writ petition---Court reaffirmed that while no vested right to promotion exists, a civil servant has a constitutional and statutory right to fair consideration for promotion under law---Constitutional petition was held maintainable under Art. 199 as the supersession, based on extraneous and procedurally flawed considerations, constituted a violation of fundamental rights---Relied on Orya Maqbool Jan v. Federation of Pakistan (2014 SCMR 817), Secretary Establishment v. Aftab Ahmad Maneka (2015 SCMR 1006), and I.A. Sherwani v. Government of Pakistan (1991 SCMR 1041). (d) Principles of Natural Justice ----Quasi-judicial forums---Application---CSB, while exercising promotion functions, acts in a quasi-judicial capacity and is bound to follow principles of natural justice---Reports introduced at the last moment without prior disclosure to the affected civil servant and without granting a hearing amount to a serious procedural irregularity---Court criticized the manner in which the intelligence reports were accepted uncritically despite lacking credibility or substantiation, and without affording petitioner any opportunity to counter them. (e) Observations on Administrative Governance ----Court strongly condemned the practice of allowing unverified intelligence reports to dictate promotion outcomes---Lack of procedural framework to govern use of such reports poses serious risks to administrative integrity and undermines morale within civil services---Promotion decisions must be merit-based and consistent with record, not influenced by fear or manipulation through anonymous allegations. (f) Disposition Petition was allowed. CSB decision dated 01.08.2023 superseding the petitioner was set aside. CSB was directed to reconsider the petitioner’s promotion to BPS-21 in its next meeting from the date of supersession, strictly in accordance with CSPR criteria and without reliance on intelligence reports not subjected to due process or rebuttal.