Orders rejecting transfer representations must give reasons and address relevant policy provisions.

The petitioner, who claimed to have a 40% physical disability, challenged his transfer and the rejection of his representation seeking retention at his existing posting.

In an earlier writ petition, the High Court had directed the respondents to consider his representation in light of the transfer policy.

The petitioner relied on Clause 28 of the policy, asserting that he could be transferred only at his own cost. Respondent No. 3 rejected his representation by order dated 21.09.2026, stating that no satisfactory reason had been disclosed, but without explaining its consideration of the petitioner’s grounds.

The petitioner brought this second writ petition under Article 226, challenging that rejection as unreasoned.

Whether the order rejecting the petitioner’s representation was invalid for failing to give reasons and address the grounds raised in the representation

Whether the respondents should be directed to reconsider the representation, including the petitioner’s reliance on Clause 28 of the transfer policy, and what interim relief should apply pending that decision

Article 226 of the Constitution empowers the High Court to review administrative action.

The Court applied the principle that administrative or quasi-judicial decisions affecting a person’s rights must disclose the reasons for the decision; reasons demonstrate that relevant considerations were addressed, constrain arbitrary discretion, and facilitate judicial review.

It relied on State of Punjab v. Bandeep Singh, (2016) 1 SCC 724, for the rule that an administrative or executive decision must be self-sustaining and informed by reasons.

Kranti Associates Pvt. Ltd. v. Masood Ahmed Khan, (2010) 9 SCC 496, for the requirement that reasons be cogent and that a rubber-stamp response is not a valid decision-making process.

Clause 28 of the applicable transfer policy was also relevant to the reconsideration directed by the Court.

The rejection order stated, in substance, that no satisfactory reason had been given and that the transfer would therefore remain unchanged, but did not set out how the petitioner’s factual grounds or reliance on Clause 28 had been considered.

Applying the requirement of reasoned decision-making, the Court found the order non-speaking and incapable of showing that the representation had been considered on relevant grounds.

The Court did not decide whether the petitioner was entitled to remain at his existing posting; instead, it required a fresh decision that addressed Clause 28.

Pending that decision, the transfer order dated 15.06.2026, insofar as it related to the petitioner, was stayed; no coercive action was to be taken against him, and he was to continue at the Primary Health Centre, Sayar, District Vidisha.

The petition was disposed of.