Administrative transfers warrant no judicial interference absent substantiated mala fides or statutory violation.

The applicant, a Chief Loco Inspector under North Central Railway, was transferred from Jhansi to Juhi by order dated 13 February 2026 on the stated ground of administrative necessity.

He challenged the transfer, contending that numerous Chief Loco Inspector posts were vacant at Jhansi, whereas only two posts were vacant at Juhi; that he had been reposted to Jhansi on 11 October 2024 and transferred again after approximately fourteen months; and that junior employees had been retained at Jhansi.

He also relied on his wife’s medical condition and his son’s fourth-year MBBS course at Jhansi.

The applicant had earlier filed O.A. No. 231 of 2026. By order dated 27 February 2026, the Tribunal directed the respondents to consider his representation dated 23 February 2026, specifically keeping in view his wife’s medical condition, his son’s educational commitments and the availability of vacancies at Jhansi.

The representation was rejected by order dated 8 May 2026.

The rejection order relied on increased movement of DFCCIL goods trains from Kanpur and also questioned the authenticity of a medical certificate submitted by the applicant.

The applicant challenged both the transfer order and the rejection order, alleging arbitrariness, discrimination, mala fides, violation of the transfer policy, non-compliance with the Tribunal’s earlier directions and lack of authority on the part of Respondent No. 5.

The respondents maintained that the transfer was made in administrative interest, that Respondent No. 5 continued to hold charge at Jhansi until 14 May 2026, and that the representation had been duly considered through a reasoned order.

Whether the transfer order dated 13 February 2026 was liable to be quashed as arbitrary, discriminatory, mala fide or contrary to the applicable transfer policy.

Whether the applicant could invoke Clause 4.2(i) of Master Circular No. 24, requiring the junior-most employee to be transferred first in cases of cadre curtailment.

Whether the rejection order dated 8 May 2026 complied with the Tribunal’s earlier direction to consider the applicant’s representation and relevant personal circumstances.

Whether Respondent No. 5 lacked authority to pass the rejection order because he had been transferred from Jhansi to Prayagraj on 7 May 2026.

Whether the alleged mala fides, earlier disciplinary proceedings and disputed medical certificate established a legally sustainable ground for judicial interference.

Section 19 of the Administrative Tribunals Act, 1985 confers jurisdiction on the Tribunal to adjudicate service-related grievances.

Master Circular No. 24 provides that transfers may be made for administrative requirements and that transfer is not a punishment; its Clause 4.2(i), requiring transfer of the junior-most employee as a general rule, applies where there is curtailment in a cadre.

Transfer is ordinarily an incident of service, and judicial interference is limited unless the order is vitiated by mala fides, violation of a statutory provision or other recognised legal infirmity.

In Union of India v. Ashok Kumar, (2005) 8 SCC 760, the Supreme Court held that the burden of proving mala fides is heavy and requires material of a high order of credibility.

State of Haryana v. Ch. Bhajan Lal, 1992 Supp (1) SCC 335, was relied upon for the principle that an unsubstantiated allegation of mala fides cannot, by itself, justify interference.

The Tribunal also relied on Pubi Lombi v. State of Arunachal Pradesh, (2024) 12 SCC 292, reiterating the restricted scope of judicial review in transfer matters.

The Tribunal found that the transfer order expressly recorded the ground as “On Administrative ground as CLI (Line)” and accepted the respondents’ explanation that increased DFCCIL goods-train operations created an administrative requirement at Juhi.

The transfer of another employee, Shri D.N. Dubey, from Banda to Jhansi was treated as an own-request transfer and therefore did not demonstrate discriminatory treatment.

Clause 4.2(i) of Master Circular No. 24 was held inapplicable because the applicant failed to establish that the transfer resulted from cadre curtailment; the respondents’ case was based instead on administrative requirements arising from increased train operations.

The Tribunal further held that the rejection order addressed the administrative justification, the applicant’s personal circumstances, the medical certificate and other grounds raised in the representation.

Consequently, the earlier direction to pass a reasoned and speaking order had been complied with, even though the decision was adverse to the applicant.

The challenge to Respondent No. 5’s authority also failed because the respondents established that he continued to hold charge at Jhansi until 14 May 2026, notwithstanding the issuance of his transfer order on 7 May 2026.

Finally, the Tribunal held that the earlier disciplinary proceedings, the subsequent cancellation of the minor penalty and the dispute regarding the medical certificate did not establish any nexus between the alleged mala fides and the impugned transfer.

The applicant’s personal and family difficulties, even if genuine, could not invalidate a transfer otherwise made in administrative interest.

In the absence of cogent evidence of mala fides, statutory violation or incompetence of the authority, judicial interference was unwarranted.

It further upheld the rejection order dated 8 May 2026, finding that it was passed by an officer who continued to hold administrative charge and that it complied with the Tribunal’s earlier direction to consider the applicant’s representation through a reasoned and speaking order.

No order was made as to costs, and all pending miscellaneous applications were disposed of.