🔍DEMOTION IN RANK CAN'T BE ARBITRARY📜
- Subhodeep Chattopadhyay
- Oct 27, 2025
- 15 min read
Updated: Nov 4, 2025
⚖️ Employee Reversion Rights: Chhattisgarh HC Rules You Can't Be Demoted to Your Lowest Post | Complete Legal Analysis 📋
🔍 Key Takeaway
In a landmark judgment that protects employee rights, the Chhattisgarh High Court has ruled that government employees facing disciplinary action can only be reverted to the immediate lower post from which they were promoted—not to the lowest post they ever held. This decision, delivered on October 14, 2025, has significant implications for lakhs of government employees across India.
Citation: 2025:CGHC:51086-DB | Writ Petition (S) No. 371 of 2025
📖 Background of the Case: C.C.S. Rao vs Union of India
The Employee's Career Progression 🚂
C.C.S. Rao, a 59-year-old railway employee, had an exemplary career trajectory with South East Central Railway, Bilaspur:
Technician Grade-III (Pay Scale: Rs. 5200-20200/- + GP 1900 PB-1) - Original Appointment
Technician Grade-II (Pay Scale: Rs. 5200-20200/- + GP 2400 PB-1)
Technician Grade-I (Pay Scale: Rs. 5200-20200/- + GP 2800 PB-1)
Master Craftsman (Pay Scale: Rs. 9300-34800/- + GP 4200 PB-2)
Junior Engineer (Electrical) (Pay Scale: Rs. 9300-34800/- + GP 4200 PB-2) - Final Position
This progression represented years of dedicated service and professional growth through multiple promotional levels.
The Disciplinary Action ⚠️
Date of Charge-Sheet: July 15, 2013
Allegation: Unauthorized absence from June 19, 2013 to July 15, 2013 (27 days)
Initial Punishment: After conducting a departmental enquiry, the Disciplinary Authority imposed the extreme penalty of removal from service without sanctioning of compassionate allowance with immediate effect on March 11, 2014.
The Appeals Process 🔄
First Appeal - Appellate Authority (June 5, 2014)
The Appellate Authority modified the punishment to:
Reversion from Junior Engineer (Electrical) to Technician Grade-III
Duration: 3 years
Pay Fixed: Rs. 5200/- + Rs. 1900/- (GP)
After completion: Restoration to Rs. 13960/- + GP Rs. 4200/-
Posting: Birsinghpur TSS under ADEE/TRD/Manendragarh
The intervening period from termination to reinstatement treated as Dies Non
Revision Petition - Revisional Authority (February 6, 2015)
The Revisional Authority:
Upheld the reversion to Technician Grade-III
Reduced the punishment period from 3 years to 1 year
Acknowledged petitioner's overall good performance and no adverse comments
After completion: Restoration to Junior Engineer post
New Posting: Kargi Road OHE Depot
Central Administrative Tribunal, Jabalpur (November 8, 2024)
The Tribunal dismissed the petitioner's Original Application No. 200/1062/2015, affirming both the Appellate and Revisional Authority orders.
Writ Petition Before High Court
Aggrieved by the CAT order, C.C.S. Rao filed Writ Petition (S) No. 371 of 2025 before the Chhattisgarh High Court, Bilaspur.
💼 Legal Arguments Presented
Petitioner's Stand 👨⚖️
Counsel: Mr. B.P. Rao, Advocate
Primary Argument: The CAT was absolutely unjustified in affirming the reversion to Technician Grade-III.
Legal Foundation: Rule 6(vi) of the Railway Servants (Discipline & Appeal) Rules, 1968
"Reduction to a lower time scale of pay, grade, post or service, with or without further directions regarding conditions of restoration to the grade or post or service from which the Railway servant was reduced and his seniority and pay on such restoration to that grade, post or service."
Key Contentions:
✅ The rule clearly provides for "reduction to a lower time scale" - singular, not lowest
✅ A promotee can only be reverted to the immediate lower post from which promoted
✅ Cannot be reverted to the lowest post on which initially appointed
✅ Proper reversion should be from Junior Engineer to Master Craftsman
✅ Reversion to Technician Grade-III bypasses two intermediate posts (Master Craftsman and Technician Grade-I)
Respondent's Counter 🏛️
Counsel: Mr. Ramakant Mishra, Deputy Solicitor General with Mr. Rishabh Deo Singh, Advocate
Arguments:
Nature and gravity of misconduct justified the punishment
Unauthorized absence for 27 days was serious dereliction of duty
Suitable and proportionate punishment had been inflicted
No interference warranted by the High Court
Tribunal's order should be upheld
⚖️ The Division Bench's Comprehensive Analysis
The Judicial Panel 👨⚖️👨⚖️
Hon'ble Justice Sanjay K. Agrawal and Hon'ble Justice Radhakishan Agrawal
Judgment Delivered: October 14, 2025
Critical Question Framed by the Court 🎯
"Whether the Central Administrative Tribunal is justified in reaffirming the punishment of reversal from the post of Junior Engineer (Electrical) to the post of Technician Grade-III imposed upon the petitioner by the Appellate Authority, which has also been affirmed by the Revisional Authority or the petitioner ought to have been reverted from the post of Junior Engineer (Electrical) to the post of Master Craftsman, being the immediate lower post?"
Understanding "Reduction in Rank" 📚
The Court extensively analyzed the legal meaning of "rank" in the context of disciplinary proceedings:
Key Observation:
"The expression 'rank', in the concept of 'reduction in rank' refers to the stratification of the positions or grades or categories in the official hierarchy."
This means:
Each promotional post represents a distinct rank
Hierarchy must be respected even in punishment
Reduction means moving down ONE stratification level
Cannot skip intermediate levels
📖 Landmark Supreme Court Precedents Cited
1. Hussain Sasan Saheb Kaladgi v. State of Maharashtra [(1988) 4 SCC 168] 🏛️
Principle Established:
The Supreme Court categorically held:
"A direct recruit to a post, it cannot be gainsaid, cannot be reverted to a lower post. It is only a promotee who can be reverted from the promotion post to the lower post from which he was promoted. These propositions are so elementary that the same are incapable of being disputed and have not been disputed."
Application to Present Case:
C.C.S. Rao was promoted from Master Craftsman to Junior Engineer
He can only be reverted to Master Craftsman
Cannot be reverted to Technician Grade-III (two levels below)
The principle is "elementary" and "incapable of being disputed"
2. Nyadar Singh v. Union of India and Others [(1988) 4 SCC 170] ⚖️
Principle Established:
The Supreme Court held that reduction in rank effects removal from a class, grade or category of post to a lower (singular) class or grade or category.
Relevant Extract (Paragraph 19):
The Court referred to P.V. Srinivasa Sastry v. Comptroller & Auditor General of India [(1979) 3 SLR 509] and observed:
"It is no doubt true that normally penalty of 'reduction in rank is imposed only so as to bring down a civil servant to a lower time scale, grade, service or post, held earlier by him before promotion and not below the post, grade, service, or time scale to which a civil servant was directly recruited, and it appears, that it is also reasonable to do so."
Key Takeaways:
Reduction means bringing down to the post "held earlier before promotion"
Not to any post below the directly recruited post
This interpretation is "reasonable" and normative
🎯 The Court's Definitive Findings
Analysis of Promotional Hierarchy 📊
The Court meticulously outlined the promotional chain:
Level 5: Junior Engineer (Electrical)
Pay: Rs. 9300-34800/- + GP 4200 PB-2
↓ CURRENT POSITION
===================================
Level 4: Master Craftsman ✅ CORRECT REVERSION
Pay: Rs. 9300-34800/- + GP 4200 PB-2
↓ SKIPPED
===================================
Level 3: Technician Grade-I ❌ SKIPPED
Pay: Rs. 5200-20200/- + GP 2800 PB-1
↓ SKIPPED
===================================
Level 2: Technician Grade-II ❌ SKIPPED
Pay: Rs. 5200-20200/- + GP 2400 PB-1
↓ WRONG REVERSION
===================================
Level 1: Technician Grade-III ❌ INCORRECT
Pay: Rs. 5200-20200/- + GP 1900 PB-1
(ORIGINAL APPOINTMENT)
Here, the level is mentioned for explanation. These levels have no relation with the level of pay mentioned in the 7th pay commission for central government employees.
The Court's Categorical Holding 📜
The Division Bench held unequivocally:
"It is quite vivid that the Appellate Authority as well as the Revisional Authority, both are unjustified in imposing the penalty of reversal from the post of Junior Engineer (Electrical) to the post of Technician Grade-III upon the petitioner as he ought to have been reverted to the lower post of Master Craftsman, which he was holding prior to being promoted to the post of Junior Engineer (Electrical), rather he has been reverted to the lowest post of Technician Grade-III to which he was originally appointed, which is unsustainable and bad in law."
Legal Principles Affirmed ✅
Immediate Lower Post Doctrine: Reversion must be to the post immediately below current position
Prohibition on Bypassing Hierarchy: Cannot skip intermediate promotional posts during reversion
Distinction Between "Lower" and "Lowest": Rule 6(vi) uses "lower" (singular) not "lowest" or "any lower"
Protection of Career Progress: Years of progressive promotions cannot be nullified in one stroke
Strict Interpretation of Penal Provisions: Disciplinary rules must be interpreted strictly, not expansively
📋 Final Order and Detailed Directions
Orders Set Aside 🚫
The Court set aside the following orders to the extent of reversion to Technician Grade-III:
❌ CAT Order dated November 8, 2024 (Annexure P-12)
❌ Revisional Authority Order dated February 6, 2015 (Annexure P-8)
❌ Appellate Authority Order dated June 5, 2014 (Annexure P-6)
Modified Punishment Order ✅
The Court Directed:
"Petitioner stands reverted from the post of Junior Engineer (Electrical) Pay Rs. 13960/- + Rs. 4200/- (GP) in PB-2 Pay Rs. 9300-34800/- to the post of Master Craftsman pay Rs. 9300-34800/- + GP 4200 PB-2 by fixing at stage Rs. 9300/- + Rs. 4200 (GP) for a period of one year."
Conditions Maintained:
✅ Duration: One year (as reduced by Revisional Authority)
✅ Postponement of future increments during punishment period
✅ Intervening period treated as Dies Non
✅ After completion: Restoration to Junior Engineer post
✅ Posting arrangements as per Revisional Authority order
✅ Petitioner entitled to consequential benefits, if any
Outcome 🎊
Writ Petition: PARTIALLY ALLOWED
Cost: No order as to costs
🌟 Significance and Far-Reaching Implications
For Government Employees 👥
1. Protection Against Arbitrary Punishment
Authorities cannot arbitrarily bypass intermediate posts
Legal framework provides clear boundaries
Even in misconduct cases, procedural fairness must be maintained
2. Recognition of Career Progression
Years of service and multiple promotions create legitimate career hierarchy
Each promotion represents enhanced responsibility and competence
Cannot be nullified through one disciplinary action
3. Proportionality in Penalties
While misconduct must be punished, punishment must be legally sound
Severity of misconduct doesn't justify legal violations
"Lower" means immediate lower, not any lower or lowest
4. Clarity on Rule 6(vi) Application
"Reduction to a lower time scale" interpreted definitively
No scope for arbitrary interpretation by disciplinary authorities
Binding precedent for all similar cases
For Railway Employees Specifically 🚂
Direct Impact:
All Railway Servants governed by Railway Servants (Discipline & Appeal) Rules, 1968
Clear roadmap for challenging improper reversion orders
Protection for those with progressive career paths
Departmental Implications:
Railway authorities must review existing reversion orders
Future disciplinary proceedings must comply with this interpretation
Training needed for disciplinary authorities on proper application
For Administrative Tribunals 🏛️
CAT's Role Clarified:
Must examine whether reversion is to immediate lower post
Cannot simply rubber-stamp departmental orders
Judicial scrutiny required on legal propriety of punishment
Standards for Review:
Proportionality of punishment ≠ Legal validity
Gravity of misconduct cannot override statutory provisions
Administrative convenience cannot trump legal requirements
For Disciplinary Authorities 📝
Mandatory Compliance:
Identify the immediate lower post before imposing reversion
Document the promotional hierarchy clearly
Ensure punishment order specifies correct post
Cannot impose reversion beyond immediate lower post
Review of Past Orders:
Similar cases may need reconsideration
Employees reverted beyond immediate lower post may seek relief
Potential for multiple writ petitions/appeals
💡 Legal Principles and Doctrines Established
1. The Immediate Lower Post Doctrine 📌
Core Principle: Reversion in disciplinary proceedings must be to the post immediately below the current position, not to the original appointment post.
Rationale:
Respects career progression
Prevents disproportionate punishment
Maintains hierarchical integrity
Application: Applies to all government servants under similar service rules
2. Hierarchical Stratification Principle 🏗️
Core Principle: "Rank" refers to specific stratification within official hierarchy; each promotional level is a distinct rank.
Implications:
Cannot collapse multiple ranks into one
Each level must be respected
Promotions create vested rights
3. Strict Interpretation of Penal Provisions ⚖️
Core Principle: Disciplinary rules imposing penalties must be interpreted strictly, not expansively.
Application:
"Lower" ≠ "Lowest"
Singular form indicates one level down
No scope for liberal interpretation favoring department
4. Protection of Career Progress 🛡️
Core Principle: Years of progressive promotions cannot be wiped out through one disciplinary action beyond immediate reversion.
Justification:
Promotions reflect merit and service
Each level represents enhanced competence
Legitimate expectation of hierarchical protection
5. Dies Non Doctrine in Service Law ⏱️
Meaning: The intervening period between termination and reinstatement is treated as "dies non" (not counted as service period).
Effect:
No pay for intervening period
No increment during this time
Service continuity for pension, but not for other benefits
📊 Comparative Analysis: What Changed?
Before This Judgment ❌
Aspect | Improper Practice |
Reversion Scope | Could be to any lower post |
Interpretation | "Lower" meant any post below current |
Authority Discretion | Wide discretion to disciplinary authorities |
Career Protection | Minimal protection for promotional hierarchy |
CAT Review | Often upheld departmental decisions |
After This Judgment ✅
Aspect | Reformed Practice |
Reversion Scope | Only to immediate lower post |
Interpretation | "Lower" means one level down specifically |
Authority Discretion | Strictly limited by hierarchical structure |
Career Protection | Strong protection for progressive promotions |
CAT Review | Must examine legal validity of reversion post |
🎓 Practical Guidance for Different Stakeholders
For Employees Facing Disciplinary Action ⚠️
Immediate Steps:
Document Your Career Path 📝
List all posts held chronologically
Note dates of each promotion
Preserve appointment/promotion orders
Identify Your Immediate Lower Post 🔍
Check promotional hierarchy
Identify post held immediately before current one
This is your protection boundary
Review the Charge-Sheet 📄
Note the alleged misconduct
Check if proper inquiry procedures followed
Engage competent legal counsel
Challenge Improper Reversion ⚖️
If reverted beyond immediate lower post, immediately appeal
Cite C.C.S. Rao vs Union of India (2025:CGHC:51086-DB)
Also cite Hussain Sasan Saheb Kaladgi (1988) 4 SCC 168
Maintain Service Records 📂
Keep copies of all orders
Document your performance record
Note absence of adverse remarks (if applicable)
Rights You Must Know 📋
✅ Right to be reverted only to immediate lower post
✅ Right to departmental inquiry with reasonable opportunity
✅ Right to appeal against punishment orders
✅ Right to approach Administrative Tribunals
✅ Right to file writ petition before High Courts
✅ Right to cite binding precedents
✅ Right to consequential benefits after restoration
For Legal Practitioners 👨⚖️
Drafting Strategy:
In Writ Petitions:
Clearly outline promotional hierarchy
Demonstrate which post is immediate lower
Cite Rule 6(vi) of relevant service rules
Rely on C.C.S. Rao, Hussain Sasan Saheb Kaladgi, and Nyadar Singh
Argue "unsustainable and bad in law" for improper reversion
In Appeals Before Appellate Authorities:
Submit detailed service record
Show absence of adverse remarks (if applicable)
Request specific reversion to immediate lower post only
Cite this judgment as binding precedent
In CAT Applications:
Challenge both quantum and nature of punishment
Argue legal invalidity of reversion to non-immediate post
Request CAT to examine hierarchical structure
Seek restoration with consequential benefits
For Disciplinary Authorities 📋
Checklist Before Imposing Reversion:
✅ Step 1: Identify current post of delinquent employee
✅ Step 2: Obtain complete service record showing all promotions
✅ Step 3: Map out promotional hierarchy clearly
✅ Step 4: Identify immediate lower post (one level down)
✅ Step 5: Draft punishment order specifying correct post
✅ Step 6: Ensure order mentions pay scale of reversion post
✅ Step 7: Specify duration of reversion clearly
✅ Step 8: Mention restoration conditions after punishment period
What to Avoid 🚫
❌ Reverting to original appointment post directly
❌ Bypassing intermediate promotional posts
❌ Using vague language like "suitable lower post"
❌ Ignoring Supreme Court precedents
❌ Justifying improper reversion based on misconduct gravity
❌ Assuming administrative convenience overrides law
🌐 Broader Context in Indian Service Law
Constitutional Framework 📜
Article 311 of Constitution
While this case doesn't directly involve Article 311 (protection against dismissal), it touches upon principles of procedural fairness and due process in disciplinary proceedings.
Rule of Law in Administration
This judgment reinforces that even in disciplinary matters, administrators are bound by:
Statutory provisions
Judicial precedents
Principles of natural justice
Reasonable and proportionate action
Service Law Jurisprudence Evolution 📈
From Employer Discretion to Employee Rights
Pre-1980s: Wide discretion to government as employer
1980s-2000s: Emergence of proportionality doctrine
Post-2000: Recognition of legitimate expectations
Current: Strong protection for career progression rights
Judicial Review of Administrative Action
Courts increasingly scrutinize:
Legality of punishment
Procedural compliance
Proportionality
Reasonableness
Consistency with precedent
Comparative Position 🌍
Other Jurisdictions:
UK: Similar protection under employment law
Australia: Fair Work Commission reviews proportionality
Canada: Duty of fairness in administrative proceedings
India: Robust judicial oversight through writ jurisdiction
🔮 Potential Future Implications
Likely Legal Developments 📊
Increase in Similar Petitions: Employees improperly reverted may file writ petitions citing this judgment
Departmental Reviews: Government departments may suo motu review and correct past orders
CAT Jurisprudence: Central/State Administrative Tribunals will align their decisions with this precedent
Legislative Clarifications: Service rules may be amended to explicitly incorporate immediate lower post principle
Training Mandates: DoPT may issue guidelines for all departments
Impact on Pending Cases ⚖️
Cases with similar facts pending before CATs may be decided in favor of employees
High Courts may follow this ratio in analogous situations
Supreme Court may affirm this principle if appeals arise
📞 FAQs - Frequently Asked Questions
Q1: Does this judgment apply to state government employees? 🏛️
Answer: Yes, the principle is applicable to all government employees governed by similar service rules that provide for "reduction to lower post/rank." While this case specifically dealt with Railway Servants Rules, 1968, the Supreme Court precedents cited (Hussain Sasan Saheb Kaladgi and Nyadar Singh) are binding across India.
Q2: What if I was reverted 5 years ago to a lower post beyond immediate? Can I still challenge it? ⏰
Answer: You may face limitation issues as writ petitions typically have a limitation period. However, if you can demonstrate:
Continuing wrong (if still serving in wrong post)
Lack of knowledge of legal rights
Just cause for delay
You may file a petition with an application for condonation of delay. Consult a lawyer immediately.
Q3: Does this judgment apply to private sector employees? 🏢
Answer: No, this judgment specifically deals with government servants under statutory service rules. Private sector employees are governed by their employment contracts and applicable labor laws. However, principles of fairness and reasonableness apply across sectors.
Q4: What is "Dies Non" mentioned in the judgment? 📅
Answer: "Dies Non" literally means "not a day" - it's a legal fiction where the intervening period between termination and reinstatement is treated as if it never existed for service benefits (except for pension continuity in some cases). You won't get pay or increments for this period.
Q5: Can the department now re-impose fresh punishment correctly? 🔄
Answer: No. In this case, the Court modified the existing punishment by changing the reversion post to Master Craftsman. The department cannot re-initiate proceedings for the same charges once punishment is finalized. The principle of double jeopardy applies.
Q6: What if there are multiple promotions on the same pay scale? 💰
Answer: Each promotional post represents a distinct rank regardless of pay scale. In C.C.S. Rao's case, both Master Craftsman and Junior Engineer had the same pay scale (Rs. 9300-34800/- + GP 4200 PB-2), yet they were distinct posts. Reversion must be to Master Craftsman, not any lower post.
Q7: Does the nature of misconduct matter? ⚖️
Answer: While grave misconduct may justify harsher punishment (like removal from service), it cannot justify bypassing legal requirements for reversion. The Court made it clear that regardless of misconduct severity, reversion must be to immediate lower post only. Gravity may determine whether reversion is appropriate, but not to which post.
📝 Case Details Summary
Detail | Information |
Case Name | C.C.S. Rao vs Union of India & Others |
Case Number | Writ Petition (S) No. 371 of 2025 |
Citation | 2025:CGHC:51086-DB |
Court | High Court of Chhattisgarh at Bilaspur |
Bench | Division Bench |
Judges | Justice Sanjay K. Agrawal & Justice Radhakishan Agrawal |
Judgment Date | October 14, 2025 |
Petitioner | C.C.S. Rao (Age: 59 years) |
Petitioner's Address | R.T.S. Colony, S.E.C. Railway, Bilaspur-495004 |
Respondents | Union of India & 3 Others (Railway Authorities) |
Petitioner's Counsel | Mr. B.P. Rao, Advocate |
Respondent's Counsel | Mr. Ramakant Mishra, DSG with Mr. Rishabh Deo Singh |
Subject Matter | Challenge to reversion order in disciplinary proceedings |
Result | Writ Petition Partially Allowed |
Cost | No Order as to Costs |
📚 Key Citations and References
Primary Authorities:
C.C.S. Rao vs Union of India & Others
Citation: 2025:CGHC:51086-DB
Court: Chhattisgarh High Court
Hussain Sasan Saheb Kaladgi v. State of Maharashtra
Citation: (1988) 4 SCC 168
Court: Supreme Court of India
Nyadar Singh v. Union of India and Others
Citation: (1988) 4 SCC 170
Court: Supreme Court of India
P.V. Srinivasa Sastry v. Comptroller & Auditor General of India
Citation: (1979) 3 SLR 509
Court: Karnataka High Court (cited by SC)
Statutory/Constitutional Provisions:
Railway Servants (Discipline & Appeal) Rules, 1968
Rule 6(vi) - Penalties - Reduction to lower post
Constitution of India
Article 226 - Writ Jurisdiction of High Courts
🎯 Conclusion
The Chhattisgarh High Court's decision in C.C.S. Rao vs Union of India (2025:CGHC:51086-DB) marks a significant milestone in Indian service law jurisprudence. By holding that reversion must be to the immediate lower post only and declaring reversion to the lowest post as "unsustainable and bad in law," the Court has:
✨ Key Achievements:
🔹 Protected years of career progression from being arbitrarily nullified 🔹 Clarified ambiguous statutory language with definitive interpretation 🔹 Set binding precedent for thousands of similar cases 🔹 Reinforced Supreme Court principles in practical context 🔹 Checked administrative overreach in disciplinary proceedings 🔹 Ensured proportionality between misconduct and punishment
🌟 Lasting Impact:
This judgment serves as a powerful reminder that:
Even in disciplinary proceedings, legal propriety cannot be sacrificed at the altar of administrative convenience or citing the severity of misconduct.
For government employees across India, particularly those in Railways and other organized services, this decision provides:
Legal shield against arbitrary reversion
Clear roadmap for challenging improper orders
Judicial recognition of career progression rights
Enforceable standards for disciplinary authorities
For administrators and disciplinary authorities, it establishes:
Mandatory compliance framework
Clear dos and don'ts in imposing reversion
Need for legal training in service matters
Accountability for legally unsustainable orders
💬 Final Thoughts
This judgment beautifully balances the need for maintaining discipline in government services while protecting the legitimate career expectations of honest, hardworking employees who have progressively built their careers over decades. It stands as a testament to the robustness of Indian constitutional jurisprudence and the vital role of courts in checking administrative excess.
The message is clear:
✅Discipline: yes, but within the bounds of law.
✅Punishment: yes, but not beyond legal limits.
✅Administrative convenience: yes, but not at the cost of justice.
🔖 Keywords & Tags
C.C.S. Rao Case Chhattisgarh High Court 2025 Employee Reversion Rules Immediate Lower Post Doctrine Railway Servants Discipline Rules Service Law Landmark Judgment Government Employee Rights Disciplinary Proceedings Administrative Law Rule 6(vi) Interpretation Career Progression Protection Hussain Sasan Saheb Kaladgi Nyadar Singh Precedent CAT Jurisdiction Writ Petition 371/2025 Employment Law India Justice Sanjay K Agrawal Railway Employee Rights
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