In a significant setback to the Union government, the Delhi High Court on October 17, 2025, dismissed a review petition filed by the Union of India and others against a previous order that had directed the authorities to promote IRS officer Sameer Dnyandev Wankhede. The division bench, led by Justice Navin Chawla and Justice Madhu Jain, came down strongly on the Centre for concealing material facts and imposed a cost of ₹20,000 to be deposited with the Delhi High Court Bar Clerks Association.
Background
The controversy traces back to a sealed-cover procedure in a Departmental Promotion Committee (DPC) held on March 18, 2024, to assess Wankhede's promotion to Additional Commissioner. Despite a clean record at the time, his promotion was inexplicably kept in a sealed cover - a move later challenged before the Central Administrative Tribunal (CAT).
In December 2024, the Tribunal ruled in Wankhede’s favour, directing the government to open the sealed cover and, if recommended by the UPSC, promote him with effect from January 1, 2021. However, the government delayed implementation and instead approached the Delhi High Court. The High Court in August 2025 upheld the Tribunal’s decision and instructed compliance within four weeks.
Rather than complying, the government returned with a review petition, arguing that a charge memorandum issued against Wankhede on August 18, 2025-before his promotion was granted-justified keeping his name sealed once again.
Court's Observations
The bench did not mince words while rejecting the government’s reasoning. Justice Chawla remarked that the charge memo issued after the Court had reserved judgment could not become a valid ground to reopen the case.
"This was not a cause of action before us, and therefore, we refrain from making any observations on the same," the Court clarified.
The judges also expressed displeasure at the government's conduct in hiding the fact that the Tribunal had already restrained departmental proceedings against Wankhede through an order dated August 27, 2025.
"We strongly deprecate the conduct of the review petitioners in concealing from this Court the fact that the learned Tribunal had restrained them from proceeding further," the bench observed.
The Court emphasized that the State must act fairly and with complete transparency, noting that the review petitioners, being a State, are expected to disclose all relevant facts truthfully before this Court.
Decision
Concluding its order, the bench stated that there were no valid grounds to review its earlier judgment and dismissed the review petition. The Court further directed the government to pay ₹20,000 as costs within four weeks.
"The reasons advanced are insufficient to recall or modify our earlier judgment," the order read. The Court made it clear that if the government believes new developments justify withholding promotion, it must pursue a separate legal process rather than misuse a review petition.
With this ruling, the Delhi High Court reaffirmed that administrative delays and sealed-cover tactics cannot be used to withhold promotions without lawful justification especially when higher courts and tribunals have already spoken on the matter.
Case Title: Union of India and Others vs Sameer Dnyandev Wankhede
Case Number: W.P. (C) 10271/2025
Petitioner's Counsel:
Mr. Ashish K. Dixit, Central Government Standing Counsel (CGSC)
with Mr. Adhiraj Singh, Government Pleader,
Mr. Umar Hashmi, Mr. Mayank Upadhyay,
Mr. Harshit Chitransh, Ms. Iqra Sheikh, Advocates.
Respondent's Counsel:
Mr. T. Singhdev, Mr. Jatin Parashar, Mr. Rohit Bhagat,
Ms. Yamini Singh, Mr. Abhijit Chakravarty,
Ms. Ramanpreet Kaur, Mr. Tanishq Shrivastava,
Mr. Sourabh Kumar, Mr. Vedant Sood, and Mr. Bhanu Gulati, Advocates.
