Administrative authorities must consider medical hardships and record reasoned findings when deciding transfer representations.

The applicant, a Material Assistant at the Central Ordnance Depot (COD), Delhi, was transferred to the 41 Field Ammunition Depot in Leh, Ladakh via an order dated 14.02.2026.

The applicant suffers from acute asthma, hypertension, and respiratory issues, supported by a medical certificate dated 21.01.2026, which stated he is unfit for duty at high altitude and extreme cold.

He submitted a representation on 02.03.2026 highlighting these medical hardships.

However, the respondents issued a subsequent order on 06.05.2026 rejecting his plea without providing specific reasons and directing him to report to Leh.

The applicant challenged these orders before the Tribunal seeking to set aside the transfer.

1. Whether the respondents are required to consider personal medical hardships and provide a reasoned order when deciding on an employee's representation against a transfer order.

2. Whether the applicant is entitled to interim protection from his transfer to a high-altitude area pending a fresh consideration of his grievances.

The Tribunal applied the principle that transfer is an incidence of service and judicial review is limited unless the order is mala fide or violates statutory provisions, as established in Namrata Verma v. State of U.P. (2021) and Union of India v. S.L. Abbas (1993).

Based on Rajendra Roy v. Union of India (1993), the department is reasonably expected to consider personal hardships and medical difficulties in a timely manner.

Under the doctrine established in M/s Kranti Associates Pvt. Ltd. v. Masood Ahmed Khan, even administrative decisions must be supported by recorded reasons to satisfy the principles of justice.

The Tribunal observed that while the employer has the prerogative to transfer employees based on administrative requirements, the applicant's medical condition—specifically acute asthma and hypertension—presents a "great risk of personal harm" at an altitude of 11,500 feet.

The court noted that the respondents' order dated 06.05.2026 failed to assign any reasons for rejecting the medical grounds raised in the applicant's representation.

Applying the rule that administrative bodies must record reasons to support their conclusions, the Tribunal found that the applicant's personal difficulties required a meaningful and reasoned consideration by the competent authority rather than a summary rejection.

The Tribunal held that this decision must be made independently, without being influenced by the previous rejection order of 06.05.2026.

The Tribunal ordered that no coercive steps be taken against the applicant and that he be allowed to continue at his present posting in COD, Delhi, until the representation is decided.