Gauhati High Court
Administrative and Public LawEmployment and Labour Law

Courts will not interfere with public-interest transfers absent mala fides or statutory violations.

Nidhir Ranjan Roy vs The State Of Assam And 6 Ors

Gauhati High CourtJUDGMENT: October 06, 20262 MIN READSOURCE JUDGMENT
Courts will not interfere with public-interest transfers absent mala fides or statutory violations.. Nidhir Ranjan Roy vs The State Of Assam And 6 Ors. Gauhati High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, an APDCL officer, had served at several postings, including the Central Stores Division, Silchar.

Source reference: p. 5–6

After being transferred to Udharbond in February 2026, he was transferred to Sonai by order dated 12 August 2026.

Source reference: p. 5–6

That order was modified on 18 August 2026, posting him instead to the Central Stores Division, Silchar.

Source reference: p. 5–6

Following an earlier writ petition, the petitioner’s representation against the modified transfer was considered and rejected by order dated 26 August 2026.

Source reference: p. 5–6

He challenged the transfer orders and the rejection of his representation under Article 226, arguing that returning him to an office where he had served for a long period was unreasonable and arbitrary

Source reference: p. 5–6
02

Issues

1. Whether the modified transfer posting the petitioner to the Central Stores Division, Silchar, warranted interference under Article 226 on the ground that it was unreasonable or arbitrary

Source reference: p. 6–7

2. Whether the representation-rejection order disclosed a sufficient decision-making basis for the transfer, including consideration of relevant factors

Source reference: p. 7–8
03

Law Applied

Transfer is ordinarily an incident of service and falls within the employer’s administrative prerogative; judicial interference is limited, including to cases involving mala fides or violation of statutory norms or rules

Source reference: p. 7

In exercising certiorari jurisdiction, the Court examines the decision-making process—whether relevant factors were considered and irrelevant or extraneous factors excluded—rather than reassessing the merits or adequacy of the administrative decision

Source reference: p. 7–8
04

Reasoning

The Court treated the petitioner’s prior service at Silchar as a consideration he could raise, but held that the deployment of APDCL personnel was ultimately for the employer to determine.

Source reference: p. 7–8

It found that the transfer appeared to have been made in the public interest and that the competent authority had applied its mind and assigned reasons when rejecting the petitioner’s representation.

Source reference: p. 7–8

The Court therefore found no demonstrated mala fides, breach of statutory norms, or defect in the decision-making process that would justify intervention

Source reference: p. 7–8
05

Holding

The Court held that no case for interference had been made out

The Court dismissed the writ petition. The challenged transfer and representation-rejection order were not set aside

Source reference: p. 8
Gauhati High Court

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Nidhir Ranjan RoyvsThe State Of Assam And 6 Ors

Gauhati High Court · October 06, 2026

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