Discharge of naval trainees for repeated failure in technical training is legally sustainable.

The petitioners had been selected as Sailors under the Artificer Apprentice (AA) and Senior Secondary Recruit (SSR) batches commencing in February 2020, after qualifying the aptitude and physical fitness tests.

They completed basic combat training at INS Chilka and were thereafter posted for technical training at INS Shivaji and INS Valsura.

The petitioners contended that, owing to the COVID-19 pandemic, theoretical classes were not properly conducted and they were directly assigned practical training; consequently, they failed the theoretical and practical examinations.

Show-cause notices were issued proposing their withdrawal from training and discharge.

After considering their replies, Petitioner No. 1 was discharged on 13 February 2023 and Petitioner No. 2 on 11 May 2022.

Their challenge before the Armed Forces Tribunal, Principal Bench, in OA No. 808/2023, seeking quashing of the discharge orders, reinstatement, consequential benefits and transfer to another trade, was dismissed on 28 April 2026.

The petitioners thereafter invoked Article 226 of the Constitution before the Delhi High Court.

Whether the petitioners’ discharge from the Indian Navy, following their failure to qualify the technical training examinations, was arbitrary, illegal or procedurally unsustainable, particularly in view of the alleged non-conduct of proper theoretical classes during the COVID-19 pandemic.

Whether the petitioners were entitled to reinstatement with consequential benefits or consideration for transfer to another naval trade instead of discharge.

Whether the Armed Forces Tribunal’s order dated 28 April 2026 warranted interference by the High Court in exercise of its extraordinary jurisdiction under Article 226.

The Court exercised judicial review under Article 226 of the Constitution over the order of the Armed Forces Tribunal, while applying the principle that interference is unwarranted where the Tribunal’s decision is consistent with binding or materially applicable precedent and no distinguishable feature is shown.

The proceedings before the Tribunal arose under Section 14 of the Armed Forces Tribunal Act, 2007.

The Court relied on the governing naval service framework, including paragraph 7(f) of Navy Order 34/15 and Regulation 278(4) of the Regulations for the Navy, Part III, under which trainees who repeatedly fail to qualify technical training may be discharged.

It further applied the principle that technical competence is essential in a combatant force and that the Navy is not required to retain or reassign trainees who fail to meet prescribed technical standards.

The Court followed the decisions in Akash Singh Chahar v. Union of India, Rameshwar Singh v. Union of India, and Ex EAA/APP Saunoo v. Union of India, and noted that the decision in Rameshwar Singh had been upheld by the Supreme Court on 4 November 2022.

The High Court found that the grounds raised in the writ petition were substantially identical to those already considered and rejected by the Armed Forces Tribunal and by coordinate benches in cases involving similarly situated naval trainees.

The Tribunal had considered the examination records, the respondents’ explanation regarding the petitioners’ performance, and the fact that other trainees from the same selection had successfully completed technical training and continued in service.

The earlier decisions established that repeated failure in technical subjects justified discharge because operational readiness and safe handling of sophisticated equipment require prescribed technical competence.

The Tribunal had also held that transfer to another trade could not be claimed as a matter of right, since it depended upon the availability of vacancies and the Navy’s operational requirements.

When specifically asked to identify any distinguishing feature between the petitioners’ case and the cases relied upon by the Tribunal, counsel for the petitioners was unable to do so.

Since the Supreme Court had declined to interfere with the decision in Rameshwar Singh, the High Court found no basis to adopt a different view or interfere under Article 226.

The petitioners were therefore not entitled to reinstatement, consequential benefits, or transfer to another trade.

Finding no illegality, irregularity or impropriety in the Armed Forces Tribunal’s order dated 28 April 2026, the High Court dismissed the writ petition and disposed of all pending applications.