A transfer replacing a recently posted senior with a junior, without administrative exigency, is arbitrary.

The petitioner, appointed as a Forest Guard in 2006 and later promoted to Deputy Forest Ranger, was posted as Range Assistant, Kandadi, on 19 June 2026 and joined that post.

On 10 July 2026, respondent No. 5, a junior Forester, was posted to the same position, while the petitioner was transferred to Zone Assistant, Zone East Sonpur.

The petitioner challenged both orders, contending that the transfer was made to accommodate respondent No. 5 and was contrary to the State Government policy dated 14 July 2014.

The State defended the orders as being made in the interest of administration and due to administrative exigency.

Whether the orders posting respondent No. 5 to the petitioner’s position and transferring the petitioner were arbitrary and made to accommodate respondent No. 5.

Whether the orders could be sustained when no specific administrative exigency was disclosed for replacing the petitioner with a junior employee.

The Court applied the State Government policy dated 14 July 2014 and the principle that administrative transfer or posting orders must not be arbitrary.

The judgment identifies no statute or precedent; it treated the absence of a disclosed administrative exigency, in the circumstances of this case, as relevant to whether the impugned orders were arbitrary and contrary to the policy.

The Court noted that the petitioner had joined the Range Assistant post only 20 days before the impugned orders, and that respondent No. 5 was posted to that same post before the petitioner’s transfer order was communicated.

This sequence supported the petitioner’s contention that respondent No. 5 was being accommodated.

The State’s general assertion of administrative exigency did not identify a specific reason for replacing the petitioner with a junior employee.

The Court therefore found the orders arbitrary and contrary to the applicable policy.

It quashed both orders dated 10 July 2026, while reserving liberty to the State to pass an appropriate order in accordance with law.