Disposed¶32

Jagdish Prasad Mishra v. The Union of India

Patna HC23 Mar 2026CWJC/3981/2026

Case brief

AI extract

What is this about?

CRPF transfer dispute; Summer Chain Transfer (SCT) 2026; Standing Order 04/2022 dated 27.09.2022; clause 6 and clause 6(b); hardship score (517) and total score (7768); preference/choice posting; SANTOS software; non-consideration of hardship score in disposal of representation; order dated 20.02.2026 by D.I.G (ORG) DTE, CRPF Directorate General set aside; fresh representation to D.I.G. (ORG); fresh order within 60 days; Group-C CRPF personnel transfer policy; speaking order requirement; Patna High Court civil writ jurisdiction.

What did the court decide?

Impugned order dated 20.02.2026 set aside; petitioner permitted to file a fresh representation before Respondent no.2 (D.I.G. (ORG), Directorate, C.R.P.F., New Delhi), who must pass a fresh order within 60 days of receipt; writ petition disposed of with these directions.

Jagdish Prasad Mishra Vs The Union of India — Patna HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the order dated 20.02.2026 disposing of the petitioner's representation regarding his SCT 2026 transfer could sustain when his hardship score under clause 6 of Standing Order- 04/2022 was not considered. +1 more

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Court's answer

This Court held that clause 6 of Standing Order- 04/2022 dated 27.09.2022 (preferences/hardship-score mechanism for Summer Chain Transfer) was not taken into consideration when the petitioner's representation was disposed of.

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Ratio / Principle

The order dated 20.02.2026, issued under the seal of D.I.G (ORG) DTE by the office of the Central Reserve Police Force, Directorate General, New Delhi, is hereby set aside; the petitioner is directed to file a fresh representation with a copy of the order before the D.I.G. (ORG), Directorate, C.R.P.F. (Respondent no.2).

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Key takeaways

On receipt of the fresh representation, Respondent no.2 (D.I.G. (ORG), Directorate, C.R.P.F.) shall pass a fresh order within 60 days thereafter.ratio¶31

Detailed headnote1 paragraphs

PATNA HIGH COURT (Dr. Anshuman, J) — CWJC No.3981 of 2026, decided 23-03-2026. The petitioner, a Group-C CRPF official (A.S.I./Min. G.C.), challenged the order dated 20.02.2026 disposing of his representation for consideration of his preferred posting in Summer Chain Transfer (SCT) 2026, including his first choice of JK. The Court noted Standing Order- 04/2022 dated 27.09.2022 (CRPF transfer policy), clause 6 of which provides that SCT will be done through 'SANTOS' software, that eligible personnel fill preferences/choices keeping in view vacancies and hardship score, and (clause 6(b)) that the hardship score is based on the location of unit/establishment HQr. The representation recorded the petitioner's hardship score as 517 and total score as 7768, yet its disposal contained 'no whisper' of consideration of the hardship score. Holding that clause 6 of the Standing Order had not been taken into consideration, the Court set aside the order dated 20.02.2026, directed the petitioner to file a fresh representation before the D.I.G. (ORG), Directorate, C.R.P.F., New Delhi (Respondent no.2), and required Respondent no.2 to pass a fresh order within 60 days of receipt; the writ petition was disposed of accordingly.

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IN THE HIGH COURT OF JUDICATURE AT PATNA Civil Writ Jurisdiction Case No.3981 of 2026

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======================================================

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Jagdish Prasad Mishra Son of Anil Kumar Mishra, Resident of VillageHariram Patti Katnai Anshik, P.S.- Bahariya, District- Prayagraj (U.P.), At present F/No. 111250013 A.S.I./Min. G.C. C.R.P.F., Muzaffarpur (Bihar).

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... ... Petitioner/s

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Versus

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The Union of India through Director General, Directorate General, Central Reserve Police Force, Block No.1 CGO Complex, Lodhi Road, New Delhi110003, (Ministry of Home Affairs).

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The D.I.G. (ORG), Directorate, C.R.P.F., CGO Complex, Lodhi Road, New Delhi- 110003.

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... ... Respondent/s

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======================================================

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Appearance : For the Petitioner/s : Ms. Rekha Ranjan Prasad, Advocate For the Respondent/s : Ms. Kalpana, Advocate ====================================================== CORAM: HONOURABLE MR. JUSTICE DR. ANSHUMAN ORAL ORDER

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2 23-03-2026

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Heard learned counsel for the petitioner and learned

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counsel for the Union of India.

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The present writ petition has been filed for the following relief/s:-

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“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.

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II. For the issuance of an appropriate writ directing the respondents to consider his 1^st choice i.e. for JK.

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

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Learned counsel for the petitioner submits that the

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Patna High Court CWJC No.3981 of 2026(2) dt.23-03-2026 2/4

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petitioner was working in the CRPF and by virtue of filing the present writ petition, he has challenged the order dated 20.02.2026 passed on his representation to consider his transfer of SCT (Summer Chain Transfer) 2026. Counsel submits that the Directorate General, CRPF has issued Standing Order04/2022 dated 27.09.2022 with regard to Transfer Policy of Group- ‘A’ Officers (Up to the Rank of Deputy Commandant), Group- ‘B’ & ‘C’ Officials/Personnel of the Force. Counsel submits that the petitioner is admittedly a Group-C officer. He submits that as per clause 6(b) of the said Standing Order04/2022 dated 27.09.2022, it is the policy that for SCT transfer, the hardship score for transfer will be based on the location of unit/establishment HQr at a particular place. Counsel submits that in the representation, the hardship score has been mentioned, but in the order dated 20.02.2026, it is apparent that the hardship score has not been considered at all.

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Learned counsel appearing for the Union of India submits that time may be granted to file a counter affidavit in this matter.

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This Court after hearing the parties is of the opinion that the matter is relating to transfer and granting time for filing counter affidavit shall not solve any purpose. As per the

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Patna High Court CWJC No.3981 of 2026(2) dt.23-03-2026 3/4

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Standing Order- 04/2022 dated 27.09.2022, it transpires that the Directorate General, CRPF has issued the said standing order whose clause 6 is very much relevant and reads as under:-

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“6. The Sumer Chain Transfer will be done through 'SANTOS' Software. All those who are eligible for transfer will be identified and their names will be checked and approved by concerned Unit/office. All concerned will be allowed to fill preferences/choices. After this transfer will be issued through Software.

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(a) Every officer/official/personnel will be able to give preferences/choices in various eligible Units/Offices. The maximum number of preferences which can be given in various categories will be decided by Dte. Preferences are to be filled up very carefully keeping in view of the vacancies and hardship score. Filling up the preferences is not a guarantee for posting to preferred unit/establishment. Also no officer/official/personnel can lay claim for any particular post or location.

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(b) Hardship score for transfer will be based on the location of unit/establishment HQr at a particular place. The hardship score is liable to be changed depending upon the operational and other administrative consideration of the particular area. The points for home posting will be reduced as decided by Directorate.”

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Patna High Court CWJC No.3981 of 2026(2) dt.23-03-2026 4/4

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In the representation of the petitioner, it is there that the hardship score for the petitioner was 517 & total score as 7768. But at the time of disposal of his representation, there is no whisper with regard to consideration of his hardship score.

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As such, this Court is of the view that clause 6 of the said Standing Order- 04/2022 dated 27.09.2022 quoted above has not been taken into consideration.

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In this view of the matter, the order dated 20.02.2026 issued under the seal of D.I.G (ORG) DTE by the office of Central Reserve Police Force, Directorate General, Block No.1 CGO Complex, Lodhi Road, New Delhi is hereby set aside. The petitioner is directed to file his fresh representation along with a copy of this order before the D.I.G. (ORG), Directorate, C.R.P.F., CGO Complex, Lodhi Road, New Delhi (Respondent no.2). Upon receipt of the same, the Respondent no.2 is directed to pass order afresh within 60 days thereafter.

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Accordingly, with the aforesaid direction, this writ petition stands disposed off.

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(Dr. Anshuman, J)

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Divyansh/-

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Jagdish Prasad Mishra v. The Union of India

Case brief

What is this about?

What did the court decide?

Jagdish Prasad Mishra v. The Union of India

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

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