Transfer on equivalent post upheld where no mala fides or tenure-rule breach was shown in administrative posting decision.

Transfer of a senior police officer to another Central Police Organisation on an equivalent post was upheld because judicial review in transfer matters is limited to proved mala fides or breach of an applicable rule or guideline. The allegation that the transfer was intended to defeat a sensitive investigation failed for want of material showing that the successor was unsuitable or that public interest was prejudiced. The officer's total deputation tenure remained consistent with the governing tenure rules, and the transfer was made in the ordinary course to meet administrative need. The court reiterated that it does not sit in appeal over administrative assessments of suitability in transfer decisions.

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Issues: Whether the transfer of a senior police officer from one Central Police Organisation to another, without adverse effect on service career, was vitiated by mala fides or by breach of the governing tenure rules.

Analysis: The challenge to a transfer on an equivalent post is subject to a narrow scope of judicial review, confined to proved mala fides or violation of an applicable rule or guideline. A plea that the transfer was made to defeat a sensitive investigation required material showing that the successor was unsuitable or that public interest was demonstrably prejudiced; no such foundation was laid. The record indicated that the transfer was made in the ordinary course to meet administrative need in the receiving organisation, and the officer's total deputation tenure in Central Police Organisations remained consistent with the tenure rules. The Court reiterated that courts do not sit in appeal over administrative assessments of suitability in matters of transfer.

Conclusion: The transfer was not vitiated by mala fides or by breach of the tenure rules, and the challenge failed.

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