Reasonable accommodation in transfers requires meeting specific disability thresholds defined under the employer’s administrative policy.

The Petitioner, a Primary Teacher appointed in 2009, challenged her transfer from Delhi to Babugarh Cantt., Agra Region.

In 2022, she was initially transferred to Pondicherry, which led to litigation eventually reaching the Supreme Court (SLP (C) No. 24825/2023).

Pursuant to Supreme Court directions, the Respondent-KVS invited fresh options; the Petitioner opted for Faridabad, Ghaziabad, and Noida.

Due to lack of vacancies, she was instead posted to Babugarh Cantt. (approx. 90km from her first choice).

The Petitioner sought cancellation of the transfer, citing "Bipolar Affective Disorder" and the need for family support.

The Central Administrative Tribunal (Tribunal) dismissed her Original Application (O.A. No. 4052/2024) on 17.09.2025, holding she did not meet the criteria for "Medical Disability Ground" (MDG) under the Transfer Policy.

1. Whether the transfer of the Petitioner was vitiated by illegality, perversity, or failure to exercise jurisdiction, particularly regarding her claim for reasonable accommodation on medical grounds.

2. Whether the Petitioner’s medical condition (Bipolar Affective Disorder) qualifies for exemption under the "Medical Disability Ground" (MDG) category of the KVS Transfer Policy dated 30.06.2023.

Transfer is an incident of service and an employee holds no vested right to a specific posting.

Judicial review in transfer matters is limited to cases of mala fides, statutory violation, or patent arbitrariness, as established in S.C. Saxena v. Union of India, Union of India v. S.L. Abbas, and Shilpi Bose v. State of Bihar.

The doctrine of "reasonable accommodation" under the Rights of Persons with Disabilities Act, 2016, and precedents such as Ravinder Kumar Dhariwal v. Union of India and Net Ram Yadav v. State of Rajasthan.

The KVS Transfer Policy dated 30.06.2023, specifically Annexure-I, which defines "MDG" as including diseases with "more than 50% mental disability".

The Court observed that the Respondent followed the Supreme Court’s mandate by allowing the Petitioner to exercise options and assigned her to a station (Babugarh) in proximity to her preferred choice due to administrative exigencies.

Regarding the medical claim, the Court noted that while the Petitioner suffers from Bipolar Affective Disorder, the medical certificate produced did not establish a "benchmark disability" or the "more than 50% mental disability" required to qualify for the MDG category under the Transfer Policy.

The Court reasoned that the principle of "reasonable accommodation" requires a factual foundation of disability which was not established to the requisite legal threshold here.

Since the Petitioner had served in Delhi for over 12 years and held an All-India transfer liability cadre, the transfer was deemed a valid exercise of administrative power.

It concluded that the Petitioner failed to prove her case fell within the MDG category of the Transfer Policy and that administrative interests remain paramount over personal constraints in transfer matters.

The Respondent’s decision was upheld as reasonable and in compliance with previous judicial directions, and all pending applications were closed.