The Madhya Pradesh High Court has directed the State Government to grant retrospective out-of-turn promotion to a police officer whose request had been rejected despite repeated recommendations from senior officers. The Court found that the authorities acted arbitrarily by treating an extraordinary rescue operation as a routine part of police duty.
Justice Vivek Kumar Singh passed the order while allowing a petition filed by police officer Indramani Patel, who had challenged the rejection of his claim for promotion under Regulation 70-A of the Madhya Pradesh Police Regulations.
Background of the Case
The dispute arose from an incident that took place in April 2004 when Patel was serving as a Sub-Inspector and Station House Officer at Simrol Police Station in Indore district.
According to the record, a truck loaded with bricks lost control and became suspended over a deep gorge at Bharughat after being stopped by a tree. The driver and helper remained trapped inside the vehicle and were calling for help.
The Court noted that when professional crane operators declined to descend into the gorge because of the danger involved, Patel personally climbed down using a rope. He rescued the occupants and secured the truck, preventing it from falling further.
Following the incident, local authorities and the truck owner appreciated his actions. Senior police officers, including the Superintendent of Police, Deputy Inspector General, and Inspector General, recommended his case for out-of-turn promotion.
However, a screening committee rejected the recommendation and instead awarded him a cash reward of ₹5,000.
The High Court examined Regulation 70-A, which permits accelerated promotion for police personnel who distinguish themselves through exceptional bravery or meritorious service.
Justice Singh observed that the screening committee failed to apply the correct legal standards while evaluating Patel's case.
“The petitioner went beyond the call of duty and took a life-threatening decision,” the Court observed while discussing the rescue operation.
The Court emphasized that a normal response by a police officer would have been to secure the area and call specialised rescue teams. Instead, Patel personally descended nearly 200 feet into a dangerous gorge at night and prevented a potentially disastrous accident.
The Court further noted that the authorities had adopted contradictory positions. While Patel's actions were considered brave enough to justify a cash reward, the same conduct was later labelled as routine duty when his promotion claim was considered.
“The State cannot be permitted to approbate the bravery for a cash reward and reprobate the same bravery to deny an out-of-turn promotion,” the bench said.
The Court also took note of the fact that all senior officers who had assessed the incident on the ground recommended Patel's promotion.
According to the judgment, the screening committee overturned those recommendations without providing convincing reasons and failed to comply with an earlier High Court direction requiring a fresh and objective evaluation.
Justice Singh held that the committee's decision suffered from arbitrariness, non-application of mind, and perversity.
The Court distinguished the Supreme Court's decision in State of Madhya Pradesh v. Sanjay Shukla, relied upon by the State, and held that judicial intervention was justified because the impugned decision was palpably arbitrary.
Allowing the petition, the High Court quashed the order dated 28 December 2012 rejecting Patel's claim.
The Court directed the State authorities to grant him notional out-of-turn promotion to the post of Inspector with retrospective effect from 10 February 2005, the date on which the Superintendent of Police recommended his promotion.
The Court also directed that consequential service benefits, including consideration for further promotions and fixation of seniority, be extended to him. However, it clarified that Patel would not be entitled to back wages for the period during which he had not actually worked as an Inspector.
The authorities have been directed to complete the exercise within 60 days from receipt of the certified copy of the order.
Case Details
Case Title: Indramani Patel v. State of Madhya Pradesh & Others
Case Number: Writ Petition No. 9716 of 2017
Judge: Justice Vivek Kumar Singh
Decision Date: 15 June 2026
