According to the counter affidavit filed on behalf of respondent 1, apart from Executive Engineers, Superintending Engineers and Municipal Engineer who is at the top, the Engineering Service (Civil) of respondent 1 consists of: (1) 450 Junior Engineers in the pay scale of Rs. 425 700 of which 80% is filled by direct recruitment with the 392 minimum qualification of Diploma in Civil Engineering and 20% is filled by promotion from amongst Works Assistants already in the service of respondent 1 with Diploma in Civil Engineering and minimum experience of 2 years; (2) 13 Selection Grade Junior Engineers in the pay scale of Rs. 550 900 to be filled by promotion of Junior Engineers on completion of 12 years of service on the basis of seniority; and (3) 99 Assistant Engineers in the pay scale of Rs. 650 1200 of which 50% is to be filled by promotion of Junior Engineers and 50% is to be filled by direct recruitment.