Teacher rationalization guidelines do not override administrative transfer powers absent statutory violations or mala fides.

The petitioner, an Assistant Teacher, was transferred under the teacher-rationalization policy from Government Primary School, Darripara, Block Fingeshwar, District Gariyaband, to Government Primary School, Purnapani, Block Deobhog, District Gariyaband.

She challenged the transfer and sought restoration of her original place of posting, contending that the transfer was unjustified, contrary to the applicable rationalization norms, and caused her hardship.

Her representation before the competent committee was rejected by order dated 3 June 2026, which she challenged in the present writ petition.

The State opposed the petition, relying on the Division Bench judgment in Shashi Shrivastava v. State of Chhattisgarh, WA No. 674 of 2025, decided on 18 September 2025.

Whether the petitioner’s transfer under the teacher-rationalization policy was liable to be quashed on the ground that it violated the applicable rationalization norms and caused hardship to her?

Whether the High Court ought to interfere with the transfer order and the rejection of the petitioner’s representation in the absence of demonstrated mala fides, violation of statutory rules, or lack of competence?

The Court applied the settled principle that transfer or posting is an incidence of service and ordinarily should not be interfered with by the writ court unless the order is shown to be mala fide, passed by an incompetent authority, or violative of statutory rules or regulations.

It further relied on the principle that teacher-rationalization instructions are generally guidelines and do not restrict the employer’s statutory power to post an employee in public interest or administrative exigency.

The Court also followed the binding or persuasive reasoning of the Division Bench that courts should not substitute their judgment for that of the administrative authority in matters of transfer absent legally recognized grounds for interference.

The Court found that the facts and legal issue in the present petition were identical to those considered in Shashi Shrivastava.

Applying the principle that rationalization instructions are only guidelines and that transfer is ordinarily an administrative matter, the Court held that the petitioner had not established mala fides, infringement of statutory rules or regulations, or lack of authority on the part of the respondents.

The petitioner’s claim of hardship and alleged non-compliance with rationalization norms, without proof of a legally cognizable defect in the transfer, did not justify judicial interference.

The Court therefore declined to take a view different from that adopted by the Division Bench.

The writ petition was accordingly dismissed in terms of the judgment dated 18 September 2025 in WA No. 674 of 2025.