The transfer of India’s first visually impaired woman IAS officer to Arunachal Pradesh was “the very definition of a routine or rotational transfer”, the Central Administrative Tribunal has held in setting it aside, ruling that the Rights of Persons with Disabilities Act overrides routine rotational transfer rules.
New Delhi: IAS officer Pranjal Patil, India’s first visually impaired woman IAS officer, must be continued or reposted in Delhi within four weeks, the Principal Bench of the Central Administrative Tribunal (CAT) has directed while quashing her September 2024 transfer from the Delhi segment of the AGMUT cadre to Arunachal Pradesh [Patil Pranjal Lahensingh v. Union of India & Ors.].
The order was pronounced on November 4, 2026 by Judicial Member Rajveer Singh Verma in O.A. No. 4634/2024. Orders had been reserved on October 6, 2026.
The Tribunal’s holding
The Tribunal held that the transfer was “the very definition of a routine or rotational transfer”, precisely the class of transfer from which Part H protects persons with disabilities. It ruled that the tenure requirement itself could not be treated as an administrative constraint.
“To treat the requirement of the rotational policy as the constraint that defeats the exemption from that policy would render Part H meaningless.”
On the claimed shortage of officers, the Tribunal said the burden lay on the employer, relying on the Delhi High Court’s ruling in Ircon International Ltd. v. Bhavneet Singh. Nothing had been placed on record about sanctioned and working strength, vacancies, or other officers available for posting, or why the deficit could be met only by moving “the one officer in the batch who is totally blind”. A bare assertion without particulars was held insufficient.
The officer and her transfer
Patil, a 2017-batch IAS officer, has had no perception of light since childhood and her 100 per cent visual disability is certified and undisputed. She was first allocated the Kerala cadre. In 2018, her request for an inter-cadre transfer to the Joint AGMUT cadre was accepted under a policy for officers with disabilities, and she joined the Delhi segment in January 2020 to be near specialised medical care and social support.
By an order dated September 12, 2024, the Ministry of Home Affairs transferred her to Arunachal Pradesh. A relieving order followed on October 17, 2024. After the Tribunal, in an earlier O.A. No. 4127/2024, asked the authorities to decide her representation by a reasoned order, the representation was rejected on November 6, 2024.
What each side argued
Patil argued that the transfer violated Section 20 of the Rights of Persons with Disabilities Act, 2016 and Part H of the Department of Personnel and Training instructions, which say employees with disabilities should, as far as possible, be exempted from rotational transfers. She pointed to continuing specialised ophthalmic care at the Sitaram Bhartia Institute, ICARE Eye Hospital in Noida and AIIMS, and to the death of her grandmother and sole caregiver on September 10, 2024, two days before the transfer order.
The Union government argued that AGMUT cadre officers must serve across segments, including difficult postings. It said Patil had spent nearly four years in Delhi without any tenure in a Category B segment and that Arunachal Pradesh faced a shortage of senior-scale officers. It also contended that she had accepted the multi-segment nature of the cadre when she sought the inter-cadre transfer in 2018.
Individual accommodation and estoppel
The Tribunal said reasonable accommodation is individual by nature, citing Vikash Kumar v. Union Public Service Commission and Ravinder Kumar Dhariwal v. Union of India, and found no material showing comparable specialised care or support in Arunachal Pradesh.
“Applying to a totally blind officer, without individual assessment, the same tenure rule that applies to able-bodied officers is the treatment of unequals as equals which the Hon’ble Supreme Court held to be violative of Article 14 in Net Ram Yadav.”
Rejecting the plea of estoppel, the Tribunal held that “a statutory right cannot be waived by acceptance of a general transfer liability”. It added that membership of the cadre was not an agreement that the authorities would disregard Section 20 and Part H in her case. The Delhi High Court decision in Shalu Pruthi, relied on by the respondents, was distinguished because the petitioner there had not established a benchmark disability.
The directions
Allowing the Original Application, the Tribunal:
- quashed the transfer order of September 12, 2024 (insofar as it concerns Patil), the relieving order of October 17, 2024 and the rejection order of November 6, 2024;
- directed that she be continued in, or reposted to, the NCT of Delhi segment within four weeks of receipt of a certified copy, with any intervening period regularised treating her as not at fault;
- said any future posting outside Delhi may be made only by a reasoned order after hearing her, recording the specific administrative constraint and considering her medical condition, support needs and alternative postings with comparable care;
- held that non-completion of Category B tenure on account of her disability shall not be held against her for promotion, empanelment, central deputation or any other service benefit.
No costs were imposed.
Why the order matters
The order confirms that the reasonable accommodation duty under the Rights of Persons with Disabilities Act, 2016 is not a formality that gives way to cadre management policies. Where a statute and service instructions protect employees with disabilities from rotational transfers, the employer cannot rely on the same rotation rule as the reason to deny that protection.
It also places the burden squarely on the government to prove real administrative constraints with data, and protects the officer’s career by tying Section 20(3) of the Act, which bars denial of promotion merely on the ground of disability, to tenure requirements that a disabled officer cannot meet.
Case Title: Patil Pranjal Lahensingh v. Union of India & Ors. [O.A. No. 4634/2024 with M.A. No. 2827/2026]
Bench: Rajveer Singh Verma, Member (J), Central Administrative Tribunal, Principal Bench, New Delhi
Date of Order: November 4, 2026
For the Applicant: Advocates Priyanka Bhardwaj and M.K. Bhardwaj
For the Respondents: Advocate Gyanendra Singh