Teacher rationalization guidelines do not restrict transfers made in public interest or administrative exigency.

The petitioner, an Assistant Teacher (L.B.) posted at Government Primary School, Karra, Block Masturi, challenged the transfer order dated 4 June 2025.

Under the teacher-rationalisation policy, he was transferred from Government Primary School, Karra, Limtara, Masturi, to Government Primary School, Chisda, Masturi.

He contended that the transfer was unsupported by proper justification, contrary to the applicable rationalisation and transfer norms, and caused him hardship.

The State opposed the petition, relying on the Division Bench judgment in Shashi Shrivastava v. State of Chhattisgarh & Others, WA No. 674 of 2025, decided on 18 September 2025, and submitted that teacher-rationalisation instructions were only guidelines and that transfer was an incident of service.

Whether the petitioner’s transfer order dated 4 June 2025 was liable to be quashed for allegedly violating the norms under the teacher-rationalisation and transfer policy

Whether the Court should interfere with the transfer order on the ground of hardship or alleged non-compliance with rationalisation guidelines, absent mala fides, lack of competence, or violation of statutory rules

The Court applied the principle that transfer or posting is an incident of service and ordinarily lies within the employer’s administrative discretion.

Teacher-rationalisation instructions are merely guidelines and cannot override the employer’s statutory power to post an employee in public interest or administrative exigency.

Judicial interference with a transfer order is warranted only where there is established mala fide, lack of authority or competence in the officer issuing the order, or infringement of statutory rules and regulations.

The Court further followed the binding approach adopted in the same writ appeal concerning rationalisation-related transfers.

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

Applying the principle that rationalisation guidelines do not restrict the employer’s general power of transfer, the Court declined to interfere merely because the petitioner alleged hardship or non-compliance with policy norms.

The petitioner did not establish mala fides, lack of competence of the authority passing the order, or violation of any statutory rule or regulation.

Consequently, the Court considered itself bound to adopt the same view as in WA No. 674 of 2025.

Finding the present case identical to WA No. 674 of 2025, the Court dismissed the writ petition in terms of the order dated 18 September 2025 passed in that appeal.

No separate relief was granted to the petitioner.