Rationalization instructions are mere guidelines and cannot supplant employer’s power to transfer for administrative exigency.

The petitioner, a Lecturer (LB) in English, was transferred from Govt. Boys Higher Secondary School, Sitapur (District Surguja) to Govt. High School, Chintalnar (District Sukma) via an order dated 12.06.2025.

Further consequential orders were issued on 13.06.2025, 30.06.2025, and 25.09.2025.

The petitioner challenged these orders on the grounds that they were illegal, arbitrary, and violated the Teacher Rationalization Policy, causing undue hardship.

The State contended that the matter was squarely covered by a prior Division Bench judgment in Shashi Shrivastava v. State of Chhattisgarh.

1. Whether the impugned transfer orders violated the statutory provisions or the rationalization policy governing the transfer of teachers.

2. Whether the court can interfere with a transfer order based on guidelines/rationalization instructions in the absence of proved mala fides or lack of competence.

Teacher Rationalization Instructions are merely executive guidelines and do not supplant the employer's general power under statutory service rules to post employees in the public interest or for administrative exigency.

Transfer is an incidence of service, and judicial interference is prohibited unless there is proven malice, lack of jurisdiction, or violation of statutory rules.

The Court observed that the facts and legal issues were identical to those in Shashi Shrivastava, where it was held that guidelines are not mandatory statutes that override administrative necessity.

Since the petitioner failed to prove any mala fides, infraction of statutory rules, or lack of competence by the issuing authority, the Court found no reason to deviate from the established precedent.

The Court emphasized that administrative exigency outweighs the personal convenience of the employee in transfer matters.

The Court dismissed the writ petition, holding that the transfer order was a routine incidence of service and did not warrant judicial interference.