The Central Administrative Tribunal (CAT), Allahabad Bench, has dismissed an application filed by a North Central Railway employee challenging his transfer from Prayagraj to Fatehpur, holding that the transfer was supported by administrative requirements and that the employee failed to establish that it was a disguised punishment or motivated by mala fides.
In Priya Ranjan Kumar v. Union of India & Others, Original Application No. 782 of 2025, decided on October 7, 2026, Member (Judicial) Rajnish Kumar Rai held that the transfer order dated July 25, 2025, and the consequential relieving order dated July 28, 2025, did not warrant interference.
The Tribunal observed that the Railway authorities had demonstrated an independent administrative requirement for transferring the employee, including the development of a new entry and booking office at Fatehpur Railway Station, the requirement of staff, availability of a vacant post and the employee’s continued posting in the Divisional Railway Manager’s office since 2019.
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Employee Alleged Transfer Was Punitive and Linked to Leave Dispute
The applicant, Priya Ranjan Kumar, was appointed under the Railway authorities on October 9, 2014, and had been working as CCS/CMI in North Central Railway, Prayagraj, since April 1, 2019.
He approached the Tribunal under Section 19 of the Administrative Tribunals Act, 1985, seeking quashing of the transfer order dated July 25, 2025, and the consequential relieving order dated July 28, 2025. He also sought permission to continue at Prayagraj with consequential benefits.
The employee contended that the transfer was not an ordinary administrative measure but was punitive and arbitrary. According to his submissions, disciplinary proceedings were pending against him, and the transfer would affect the competent disciplinary authority.
The applicant also alleged that the transfer was connected with a leave-related dispute and that the Railway Board’s instructions governing transfer and posting had not been followed.
He further relied upon the sequence of events involving his suspension, transfer and subsequent disciplinary proceedings to contend that the transfer was motivated by alleged misconduct.
Railway Authorities Cited New Booking Office and Staff Requirement
The Railway authorities opposed the application, maintaining that the transfer was made purely on administrative grounds.
According to the respondents, a new entry and booking office had been developed at Fatehpur Railway Station, creating an urgent requirement for staff. The applicant was transferred against a vacant post to meet that requirement.
The respondents also pointed out that the applicant had been working in the DRM office since 2019 and had completed more than four years at the station, whereas the general tenure of a Railway employee was stated to be four years.
They submitted that the transfer was recommended by the Placement Committee and approved by the competent authority after following the prescribed procedure.
The Railway authorities further contended that the transfer order was issued on July 25, 2025, while the charge-sheet was issued subsequently on July 31, 2025. They argued that the subsequent disciplinary proceedings could not establish that the transfer itself was punitive.
The respondents also denied that the transfer resulted in any change in the applicant’s disciplinary authority.
Tribunal Examines WhatsApp “OK” Response on Leave Request
An important aspect of the dispute concerned the applicant’s request for additional leave on July 17 and 18, 2025.
According to the applicant, he had availed three days of leave from July 14 to July 16, 2025, to visit his native village. On July 16, he requested two additional days of leave through WhatsApp.
He claimed that the Senior Divisional Commercial Manager/Coaching, Himanshu Shukla, had approved the request by replying “OK”.
The applicant further stated that he informed the Senior Divisional Commercial Manager/Freight telephonically on July 17, 2025.
However, the Railway authorities maintained that leave was required to be sanctioned through the HRMS portal by the competent authority and that merely submitting a leave request did not amount to approval.
The respondents stated that Himanshu Shukla was undergoing training from July 14 to July 25, 2025, and that the administrative work of the Commercial Department during that period was under the charge of Atul Yadav, Senior Divisional Commercial Manager/Freight.
According to the respondents, Atul Yadav was the competent authority for sanctioning the applicant’s leave.
The Tribunal held that the WhatsApp response “OK”, relied upon by the applicant, could not by itself be treated as conclusive proof of sanction of leave by the competent authority.
It observed that the respondents had specifically stated that leave was required to be sanctioned through the HRMS portal and that the applicant had not obtained the requisite approval for the period in question.
Tribunal Notes Transfer Order Preceded Charge-Sheet
The Tribunal considered the chronology of events while examining the allegation that the transfer was punitive.
It noted that the applicant was suspended on July 21, 2025, the transfer order was issued on July 25, 2025, and he was relieved on July 28, 2025. The charge-sheet was issued subsequently on July 31, 2025.
The Tribunal observed that although the suspension preceded the transfer, the formal charge-sheet relied upon by the applicant was issued after the transfer order.
It held that the subsequent initiation of disciplinary proceedings could not, by itself, establish that the transfer had been made as a measure of punishment.
The Tribunal also noted that the applicant had not produced sufficient independent material to establish that the transfer was connected with the alleged misconduct or that it was intended to prejudice the disciplinary proceedings.
CAT Relies on Supreme Court Ruling in Somesh Tiwari
The Tribunal referred to the principles governing judicial review of transfer orders and observed that transfer is ordinarily an incidence of service.
It reiterated that Courts and Tribunals generally do not interfere with administrative transfers made in administrative exigency or public interest.
However, interference may be warranted where a transfer is mala fide, arbitrary, contrary to statutory rules, issued by an incompetent authority or punitive in disguise without following due process.
The Tribunal relied upon the Supreme Court’s decision in Somesh Tiwari v. Union of India and Others, (2009) 2 SCC 592.
It observed that an administrative transfer cannot be used as a substitute for punishment and that a transfer made in lieu of punishment would be liable to be set aside.
The Tribunal also considered the Allahabad High Court’s decision in Dinesh Kumar Pno. No. 182462102 v. State of U.P. through Additional Chief Secretary, Department of Home, U.P., Lucknow and Others, Neutral Citation No. 2023:AHC-LKO:72738, decided on November 3, 2023.
It distinguished the said decision on the ground that the punitive character of the transfer in that case was apparent from the material considered by the Court, including the reference to alleged misconduct and inefficiency in the impugned order.
In the present case, the Tribunal found that the respondents had placed specific administrative reasons on record and that the applicant had not established that the transfer order itself was passed as punishment or in lieu of disciplinary proceedings.
Tribunal Finds No Material Establishing Mala Fides
The Tribunal observed that the Railway authorities had disclosed identifiable administrative reasons for transferring the applicant to Fatehpur.
These included the development of the new entry and booking office at Fatehpur Railway Station, the requirement of staff, availability of a vacant post and the applicant’s continued posting in the DRM office since 2019.
It further noted that the transfer had been placed before the Placement Committee and approved by the competent authority.
The Tribunal held that the applicant had failed to establish that the transfer was passed by an authority lacking competence or that it resulted in any change in the disciplinary authority.
It also observed that the allegation of mala fides could not rest merely on conjecture or presumption and required specific and cogent material.
The Tribunal concluded that the circumstances relied upon by the applicant, considered individually or cumulatively, did not displace the independent administrative basis disclosed by the respondents.
Original Application Dismissed
Holding that the Railway authorities had demonstrated a separate and bona fide administrative exigency for transferring the applicant to Fatehpur, the Tribunal found no sufficient ground to interfere with the transfer order dated July 25, 2025, or the consequential relieving order dated July 28, 2025.
Accordingly, the Original Application was dismissed.
The Tribunal also vacated the interim order dated August 19, 2025, and directed that there would be no order as to costs. All pending miscellaneous applications, if any, were disposed of.
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