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Patna High Court

Raj KumarversusThe Union of India

Decided
Disposal
DISMISSED

Holding

The court dismissed the writ petition and interlocutory application, refusing to interfere with the transfer order.

Summary

The petitioner, a Group ‘C’ employee of the CRPF, challenged his transfer from Muzaffarpur to Pune, alleging that his hardship score of 691 was ignored and that he was denied his first‑choice posting under the Summer Chain Transfer 2022. He sought a writ directing the respondents to consider his hardship and to place him in his preferred location. The Union of India contended that the transfer complied with the CRPF transfer policy, which mandates transfer after three years of tenure, and that administrative requirements justified the move. The court noted that the petitioner had completed more than three years at Muzaffarpur and that the transfer was made in accordance with the policy. Relying on a prior decision in Jagdish Prasad Mishra v. Union of India, the court found no merit in setting aside the order and dismissed the writ petition and the interlocutory application.

Issues considered

  • Whether the transfer order violated the CRPF hardship policy by not considering the petitioner's hardship score.
  • Whether the petitioner is entitled to be placed in his first‑choice posting under the Summer Chain Transfer 2022.
  • Whether the court should set aside the transfer order and direct a fresh representation within 60 days.

Subjects

  • transfer
  • hardship score
  • CRPF
  • Group C employee
  • writ petition
  • administrative policy
  • tenure
  • interlocutory application

Judgment

         IN THE HIGH COURT OF JUDICATURE AT PATNA
                     Civil Writ Jurisdiction Case No.4055 of 2026
     ======================================================
     Raj Kumar Son of Birendra Sharma, Resident of Village- Babhantoli, P.S-
     Rasul, District- Vaishali. Present Address- F/No. 135341123 ASI/Min. GC
     CRPF, Muzaffarpur.

                                                              ... ... Petitioner/s
                                      Versus
1.   The Union of India through Director General, Directorate General, Central
     Reserve Police Force, Block No.1 CGO Complex, Lodhi Road, New Delhi-
     110003, (Ministry of Home Affairs).
2.   The D.I.G. (ORG), Directorate, C.R.P.F., CGO Complex, Lodhi Road, New
     Delhi- 110003.

                                               ... ... Respondent/s
     ======================================================
     Appearance :
     For the Petitioner/s   :      Ms.Rekha Ranjan Prasad, Advocate
     For the Respondent/s   :      Mr. K. N. Singh, A.S.G
                                   Ms. Kalpana, C.G.C.
     ======================================================
     CORAM: HONOURABLE MR. JUSTICE DR. ANSHUMAN

                                ORAL JUDGMENT

      Date : 28-04-2026
                   Heard learned counsel for the petitioner and

      learned counsel for the Union of India.

                       2. Learned counsel for the petitioner submits that

      the petitioner has filed the present writ petition for the following

      relief/s :-

                                    “(i)   For     the   issuance     of    any
                     appropriate writ/commanding the respondents to
                     allow the choice post of transfer in Summer Chain
                     Transfer (SCT) in 2022.
                                    (ii)   For     the    issuance     of    an
                     appropriate Writ directing the Respondents to
                     consider his 1st Choice i.e. for JK.
Patna High Court CWJC No.4055 of 2026 dt.28-04-2026
                                           2/4




                                          (ii) For the issuance of any other
                        appropriate writ to which the petitioner is entitled
                        by this Hon’ble Court.”


                          3. Learned counsel appearing for the petitioner

         submits that the petitioner is a Group ‘C’ employee of the

         C.R.P.F., who has filed the present writ petition challenging his

         transfer from G.C., Muzaffarpur to G.C., Pune on the ground

         that his hardship score was not taken into consideration at the

         time of transfer. It is further submitted that the petitioner has a

         hardship score of 691 and had submitted a representation dated

         10.01.2025 (Annexure P-3 to the writ petition), which has been

         rejected without proper consideration of the hardship policy. It

         is also submitted that, by way of Interlocutory Application No.

         01 of 2026, the petitioner has challenged the order dated

         20.02.2026 (Annexure P/4 to the writ petition).

                          4. Learned counsel for the petitioner further

         submits that this Court, in CWJC No. 3981 of 2026 (Jagdish

         Prasad Mishra vs. Union of India & Ors.), had set aside a

         similar order dated 20.02.2026 and directed the petitioner

         therein to file a fresh representation before the respondent No. 2,

         i.e., the D.I.G. (Org), Directorate, C.R.P.F., CGO Complex,

         Lodhi Road, New Delhi, with a direction to decide the same
Patna High Court CWJC No.4055 of 2026 dt.28-04-2026
                                           3/4




         within 60 days. It is submitted that the present case stands on a

         similar footing and, therefore, a similar order may be passed.

                          5. On the other hand, learned counsel appearing

         on behalf of the Union of India submits that the aforesaid writ

         petition was decided in absence of a counter affidavit, whereas

         in the present case, a counter affidavit has already been filed. It

         is further submitted that the petitioner, being an employee of the

         C.R.P.F., was transferred from G.C., C.R.P.F., Muzaffarpur

         (Bihar) to G.C., C.R.P.F., Pune (Maharashtra) vide order dated

         07.01.2026, issued by the competent authority at the Directorate

         level, taking into account administrative requirements, vacancy

         position, tenure norms, and operational exigencies of the Force.

                          6. It is further submitted that the transfer policy

         has been brought on record, and as per Clause 8(a), a Group ‘C’

         employee is liable to be transferred after completion of three

         years of tenure. The petitioner has admittedly completed more

         than three years at Muzaffarpur and, therefore, his transfer has

         been made in accordance with the policy in the interest of the

         Force.

                          7. In light of the submissions made by the parties,

         and upon consideration of the materials available on record,

         particularly the fact that the petitioner has completed more than
             Patna High Court CWJC No.4055 of 2026 dt.28-04-2026
                                                        4/4




                      three years of tenure at Muzaffarpur, this Court is not inclined to

                      interfere with the impugned transfer order.

                                       8. Accordingly, the present writ petition stands

                      dismissed. Interlocutory Application No. 01 of 2026 also stands

                      dismissed.


                                                  (Dr. Anshuman, J)
Ashwini/-
AFR/NAFR
CAV DATE                NA
Uploading Date          28/04/2026
Transmission Date       NA


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