CAT Allahabad: WhatsApp ‘OK’ Not Proof Of Sanctioned Leave, Tribunal Upholds Railway Employee’s Transfer To Fatehpur

Does a one-word WhatsApp reply settle a leave application? WhatsApp ‘OK’ Not Proof Of Sanctioned Leave, the Central Administrative Tribunal at Allahabad has held, rejecting a railway employee’s claim that a reply from a senior officer approved his leave and that his transfer was punitive.

Allahabad High Court building in Prayagraj, the city where the CAT Allahabad Bench held a WhatsApp reply is not proof of sanctioned leave

Prayagraj: A North Central Railway employee who says a senior officer approved his leave by replying “OK” on WhatsApp has failed to get his transfer from Prayagraj to Fatehpur quashed. The Central Administrative Tribunal (CAT), Allahabad Bench, by an order dated October 7, 2026, dismissed his Original Application, holding that a one-word WhatsApp reply of “OK” cannot by itself be treated as conclusive proof that the competent authority sanctioned his leave [Priya Ranjan Kumar v. Union of India and Others].

The application, reserved on August 24, 2026, was decided by Judicial Member Rajnish Kumar Rai. The interim order dated August 19, 2025 stands vacated, and no costs were awarded.

Who the “OK” came from

The officer who sent the reply was away on training, the Tribunal noted. Charge of the department had passed to the Freight officer, who was the competent authority for the applicant’s leave, and the applicant had not obtained sanction through the HRMS portal for July 17 and 18.

“the alleged WhatsApp response “OK” relied upon by the applicant cannot, by itself, be treated as conclusive proof of sanction of leave by the competent authority, particularly when the respondents have specifically stated that, during the relevant period, the administrative work of the Commercial Department was under the charge of Shri Atul Yadav”

Leave, suspension and transfer, in the applicant’s telling

Appointed in 2014, the applicant has worked as CCS/CMI at Prayagraj since April 2019. He said he took leave from July 14 to 16, 2025 to visit his village and, on July 16, asked over WhatsApp for two more days, July 17 and 18. In his account, the Senior Divisional Commercial Manager (Coaching), Himanshu Shukla, approved this by replying “OK”.

He returned to duty on July 21, 2025 and was called to the chamber of the Senior Divisional Commercial Manager (Freight), Atul Yadav. He was suspended that day, transferred to Fatehpur by an order of July 25, relieved on July 28, and charge-sheeted on July 31, 2025.

What each side said about the transfer

The applicant argued that the transfer was punitive and arbitrary, that it would change his disciplinary authority, and that Railway Board instructions were not followed. He relied on Somesh Tiwari v. Union of India.

The Railways described the move as administrative. A new entry and booking office at Fatehpur needed staff, a vacancy existed, the applicant had been in the Divisional Railway Manager’s office since 2019, and the Placement Committee had recommended the transfer. It added that leave had to be sanctioned through the HRMS portal, and that Shukla was on training from July 14 to 25, with Yadav in charge.

Punishment in disguise, or a posting?

The Tribunal accepted the principle in Somesh Tiwari that a transfer cannot be used as a substitute for punishment, but found it did not help on these facts. It gave weight to the chronology: although the suspension came first, the transfer order of July 25 preceded the charge-sheet of July 31, so later disciplinary action did not make the transfer punitive. The Railways had also shown a separate administrative need at Fatehpur, a vacant post, and approval through the Placement Committee.

On mala fides, the Tribunal applied the settled approach that transfer is an incident of service, and that interference is warranted only where the order is mala fide, arbitrary, contrary to statutory rules, passed by an incompetent authority or punitive in disguise. It recorded the following test:

“An allegation of mala fides or malice in fact must rest upon specific and cogent facts; it cannot be founded on mere conjecture or presumption.”

The applicant also said the Freight officer could not act because he was connected with the incident. That plea failed too: the Tribunal found that the transfer did not change the disciplinary authority, and that the applicant had not shown the transferring authority lacked competence.

What the order tells employees and tribunals

For employees who rely on informal messages for leave, the order is a practical caution. Where service rules or portals require sanction by a named competent authority, a casual acknowledgment from an officer who may not hold that power will not settle the matter.

It also restates how tribunals approach challenges to transfers. A transfer will not be set aside only because disciplinary action follows or because the employee alleges bias; he must place specific material showing mala fides or punishment in disguise. The Tribunal did not rule on the pending disciplinary proceedings.

Case Title: Priya Ranjan Kumar v. Union of India and Others [Original Application No. 782 of 2025]
Bench: Rajnish Kumar Rai, Member (Judicial), Central Administrative Tribunal, Allahabad Bench
Date of Order: October 7, 2026
Appearances: Advocate Rakesh Kumar Dixit for the applicant; Advocate Anil Kumar for the respondents

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