Teacher rationalization guidelines do not override the employer’s statutory power to transfer employees.

The petitioner, an Assistant Teacher at Primary School Bhilaikhurd, was declared surplus and transferred to Primary School Girwani by order dated 4 June 2025.

After earlier proceedings resulted in directions to consider her representation, she challenged the rejection of her appeal by the State Level Committee.

She contended that respondent No. 7, a T-Cadre teacher, had been posted as Headmaster in her E-Cadre school and that this arrangement could not justify declaring her surplus.

The State relied on the Division Bench decision in Shashi Shrivastava v. State of Chhattisgarh & Others, WA No. 674 of 2025.

Whether the State Level Committee’s order rejecting the petitioner’s appeal was liable to be set aside for failing to address her specific objection concerning respondent No. 7’s posting in an E-Cadre school.

Whether the Court should interfere with the petitioner’s surplus declaration and transfer in light of the principles stated in Shashi Shrivastava.

The Court relied on the Division Bench’s decision in Shashi Shrivastava v. State of Chhattisgarh & Others, WA No. 674 of 2025, which held that teacher-rationalization instructions are guidelines and do not displace the employer’s general powers under the applicable service rules to post employees in the public interest or for administrative exigency.

Transfer or posting is ordinarily an incident of service, and judicial interference is not warranted absent demonstrated mala fides, lack of competence in the authority issuing the order, or violation of statutory rules or regulations.

The petitioner’s principal grievance was that respondent No. 7’s posting in her school had been overlooked when she was declared surplus, and that the appellate order did not address this objection.

The Court did not separately assess the cadre-posting objection; it accepted the State’s submission that the facts and issue were identical to those in Shashi Shrivastava and declined to take a different view.

It therefore applied the Division Bench’s approach to rationalization, posting, and the limited grounds for judicial interference.

The impugned orders were not set aside, and no further relief was granted.