Substantively Appointed AP Forest Range Officers Eligible For IFoS Promotion In Fresh Exercises; CAT Gives Four Applicants 4 Weeks To Seek Consideration

The four applicants, then serving as Assistant Conservators of Forests (ACFs), sought consideration for promotion to the Indian Forest Service (IFoS) against select-list years 2013–2018, relying on service they had rendered as Forest Range Officers (FROs).

They contended that FROs were members of the Andhra Pradesh Forest Service and therefore eligible for consideration.

The State respondents maintained that FROs were not part of the State Forest Service for IFoS promotion purposes.

An earlier CAT decision in a related matter had treated FROs as State Forest Service officers, but the Andhra Pradesh High Court set it aside; the Supreme Court subsequently set aside the High Court’s judgment and held that members of specified classes of the Andhra Pradesh Forest Service, including FROs, could qualify, subject to the applicable rules.

Rule 2(g) of the Indian Forest Service (Recruitment) Rules, 1966 defines “State Forest Service” to include a State service connected with forestry whose members have gazetted status, subject to Central Government approval in consultation with the State Government.

The Supreme Court held that the required approval under Rule 2(g) relates to the service, not each post, and declared that substantively appointed members of Class A of the Andhra Pradesh Forest Service—including categories 2 and 3—are members of the State Forest Service and eligible for IFoS promotion under the Recruitment Rules.

Regulation 5(2) of the Indian Forest Service (Appointment by Promotion) Regulations, 1966 requires consideration in seniority order and, among other conditions, at least eight years of continuous service in posts included in the State Forest Service.

The Supreme Court also applied the principle against granting relief in stale promotion claims, relying on P.S. Sadasivaswamy v. State of Tamil Nadu.

The Tribunal treated the Supreme Court’s decision in the related FRO litigation as resolving the legal question: FROs who are substantively appointed members of the relevant classes of the Andhra Pradesh Forest Service may be eligible for IFoS promotion, subject to the governing rules.

However, the Supreme Court had denied relief concerning past promotion exercises to the appellant in that case because of delay and the presence of senior officers, while directing that FROs be considered when a fresh exercise is initiated.

In light of that ruling, and noting that the applicants had not first made representations to the appropriate authorities, the Tribunal directed them to seek a reasoned decision rather than grant the requested retrospective consideration directly.

The authority was directed to decide those representations by a detailed and reasoned order within three months thereafter, in light of the Supreme Court’s observations in Civil Appeal No. 11000 of 2025.

The Tribunal did not itself order inclusion in the past select lists or grant promotion or consequential benefits.

The interim relief and any pending miscellaneous applications were closed; no order as to costs was made.