Authority: Gauhati High Court (High Court of Assam, Nagaland, Mizoram and Arunachal Pradesh)

Order Date: 14 October 2026

Case Overview

  • Parties: Petitioner Monalisa Bhattacharyya (wife of Pranjal Kaushik) vs Assam Power Distribution Company Limited (APDCL) and others.
  • Petition filed under WP(C)/5473/2022 challenging APDCL communication dated 01‑06‑2022 directing petitioner to undergo HR course to regularize her appointment.
  • Background: Advertisement dated 15‑05‑2011 for Assistant Manager (HR) required MBA/PGDM (HR) with two‑year full‑time HR specialization; degree in law as additional qualification.
  • Petitioner holds MBA (Finance & Marketing), one‑year PGDM (HR), LLB; appointed Assistant Manager (HR) on 12‑03‑2012, confirmed 2014, held charge of AGM (HR) on 17‑05‑2016, promoted Deputy Manager (HR) on 27‑08‑2018 (effective 16‑03‑2016), Deputy General Manager on 25‑01‑2019.
  • She completed five years as Deputy Manager (HR) and sought promotion to Assistant General Manager (HR); Board resolution dated 16‑02‑2022 (communicated 01‑06‑2022) directed her to undergo HR course.
  • Subsequent reconsideration meetings on 02‑02‑2026 and 23‑02‑2026 reaffirmed the same direction.
  • RTI response dated 06‑11‑2021 showed 8 of 9 senior HR officers are BE graduates without HR qualifications.
  • Clause (B) of APDCL Human Resource Service Rules, 2019 stipulates two‑thirds of AGM (HR) posts filled from Deputy Managers with 5 years service; one‑third by direct recruitment; cadre strength 6 with 5 vacancies.

Final Outcome

  • The Court set aside the communications dated 01‑06‑2022 and 02‑02‑2026.
  • Directed APDCL to promote Monalisa Bhattacharyya to the post of Assistant General Manager (HR) within 45 days.
  • Writ petition allowed in entirety.

Topics: Employment Law, Public Sector Promotion