The High Court classified their contentions into the following five: (i) The only basis for determination of inter se seniority of officers in a cadre whether by promotion or direct recruitment should be the date of entry into the cadre and the quota rule is 891 not available to be used for pushing up or down officers of the cadre; (ii) Even if there be any 'carry forward ' it should not extend beyond three years; (iii) Quota rule should be applied taking into account both substantive as well as temporary vacancies in the cadre; (iv) The quota rule did no longer operate in regard to the junior scale officers when the 1959 rules became operative; at any rate it was clearly so when the 1966 Rules came into force, and (v) The impugned Government order of 1980 was invalid and liable to be quashed on several grounds, one of them being that it was made without providing an opportunity to the promo tees who were adversely affected by it.