Completion of Tenure and Administrative Exigencies Preclude Judicial Interference with CRPF Personnel Transfer Orders

The petitioner, a Group ‘C’ employee serving as ASI/Min. at GC CRPF, Muzaffarpur, challenged his transfer order dated 07.01.2026, which moved him to GC CRPF, Pune.

He contended that his transfer ignored his "hardship score" of 691 and his preferred choice of Jammu & Kashmir.

He further argued that his representation dated 10.01.2025 was rejected without proper consideration of the hardship policy.

The respondents justified the transfer based on administrative requirements, tenure norms, and operational exigencies, noting that a counter-affidavit was filed to distinguish this case from previous precedents.

1. Whether the transfer of a CRPF employee is liable to be set aside if the hardship score or choice of station is not prioritized over administrative exigencies.

2. Whether the completion of a three-year tenure at a post justifies a transfer under the prevailing CRPF transfer policy.

The court applied the CRPF transfer policy, specifically Clause 8(a), which stipulates that a Group ‘C’ employee is liable for transfer upon the completion of a three-year tenure.

It further adhered to the principle that transfers made by competent authorities based on administrative requirements, vacancy positions, and operational exigencies of the Force are generally beyond judicial interference unless substantiated by a violation of statutory norms or mala fides.

The court examined the petitioner’s tenure and found he had admittedly served more than three years at Muzaffarpur.

While the petitioner relied on a previous judgment (CWJC No. 3981 of 2026) where an order was set aside for fresh consideration, the court noted that the present case was distinguishable because the Union of India had filed a counter-affidavit justifying the transfer.

The court reasoned that since the petitioner had completed his prescribed tenure, the transfer order issued by the Directorate level was in accordance with the established policy.

The court prioritized administrative requirements and the interest of the Force over the petitioner’s personal preferences and hardship score.

Consequently, the High Court declined to interfere with the impugned transfer order, dismissed the writ petition, and dismissed Interlocutory Application No. 01 of 2026.