The Supreme Court refused immediate relief to IPS officer Urvashi Sengar, holding that joining Phase-II training midway would undermine its purpose. However, the Court orally agreed that her challenge to the 1993 MHA Office Memorandum on maternity-related interruptions appeared to have substantial legal merit.
The Supreme Court declined to grant immediate relief to IPS officer Urvashi Sengar, holding that permitting her to join the ongoing Phase-II training programme at this stage would defeat the very purpose of the course, as a substantial portion of the training had already been completed.
At the same time, the Court made significant oral observations indicating that it broadly agreed with Sengar’s challenge to the 1993 Ministry of Home Affairs (MHA) Office Memorandum (OM) governing maternity-related interruptions in IPS probationary training.
A Bench observed that although Sengar’s legal arguments appeared to have merit, practical considerations prevented the Court from directing her immediate participation in the ongoing programme.
The Bench observed,
“We agree with your submission on the merits. But we cannot implement it. Three out of nine weeks are already over. You will not be able to be trained properly. It will be to your detriment,”
The Court ultimately disposed of the petition and directed the Central Administrative Tribunal (CAT) to decide Sengar’s original application independently and on its own merits, without being influenced by any observations made by the Supreme Court.
Background of the Case
Urvashi Sengar is a 2023-batch direct recruit IPS officer allotted to the Madhya Pradesh cadre. She joined the Sardar Vallabhbhai Patel National Police Academy in November 2023 for Phase-I training. While undergoing the subsequent Phase-II programme in April 2025, which largely consisted of classroom instruction, academic modules and institutional attachments, Sengar became pregnant and duly informed the Academy authorities. She delivered a child on September 20, 2025.
As the next Phase-II programme was scheduled to commence on June 22, 2026, approximately nine months after childbirth, Sengar sought permission to participate, stating that she was medically fit to undergo the training. The Academy, however, rejected her request by relying on the 1993 MHA Office Memorandum, informing her that she would have to wait and join the next batch.
Aggrieved by the decision, Sengar approached the Central Administrative Tribunal, which, by an interim order dated May 27, permitted her to participate in the programme subject to medical fitness and other formal requirements.
Following the Tribunal’s order, the Academy initially issued a communication allowing her to join the course on June 16. However, the permission was withdrawn within two days after the Union government challenged the Tribunal’s order before the Delhi High Court.
The Delhi High Court subsequently stayed the CAT’s interim order, observing that the policy was intended to safeguard the welfare of both the probationer and her infant. This prompted Sengar to move the Supreme Court.
Beyond seeking permission to join the ongoing training, Sengar has mounted a broader constitutional challenge to the 1993 Office Memorandum itself. Her petition contends that the policy imposes a blanket exclusion on pregnant IPS probationers without examining whether an individual officer is medically capable of participating in training.
She argues that the Office Memorandum fails to reflect:
- advances in modern medical science;
- evolving training methodologies;
- the principle of reasonable accommodation; and
- the constitutional guarantee of substantive gender equality under Articles 14, 15 and 21 of the Constitution.
According to the petition, decisions concerning maternity-related interruptions should be based on individualized medical assessment rather than an inflexible administrative rule.
Arguments before the Supreme Court and Observations
The matter came up after the Supreme Court, during an earlier hearing on July 8, had asked the Central government to clarify whether Sengar could be allowed to join the Phase-II IPS training programme, which commenced on June 22, 2026, at the Sardar Vallabhbhai Patel National Police Academy (SVPNPA), Hyderabad.
Appearing for the Union government, Additional Solicitor General Anil Kaushik submitted that the Phase-II course extends over nine weeks, of which three weeks had already concluded.
According to the Centre, the officer had already missed several essential components of the programme, including:
- Field training modules;
- Physical training sessions;
- Cadre-specific exercises designed for Madhya Pradesh cadre officers; and
- Other practical learning components.
The Centre further pointed out that the Academy requires 95 per cent attendance for successful completion of the programme. Since several mandatory modules had already concluded and could not be recreated individually, allowing Sengar to join midway would leave her with insufficient attendance and incomplete training.
When the Bench sought details regarding the portions already completed, the Additional Solicitor General submitted that the missed components formed an integral part of the structured curriculum and were not capable of being conducted separately.
Counsel appearing for Sengar requested the Court to permit her to attend the remaining weeks of the programme, arguing that whatever portion had already been missed could not now be recovered in any event.
The Union government opposed any relaxation of the existing policy. The Centre argued that granting an exception in one case could potentially encourage similar claims from other probationary officers, thereby affecting uniform implementation of training regulations.
However, counsel appearing for Sengar disputed this contention and informed the Court that exceptions had been granted in previous instances, where women officers were permitted either to continue or resume training despite the existence of the 1993 Office Memorandum
The Bench, however, declined to accept the submission. The Court remarked that allowing an officer to undergo only a fraction of a structured training programme would be inappropriate and could ultimately prejudice the officer herself.
Observing that it could protect her seniority if required, the Court nevertheless emphasized that incomplete training would not serve either the officer’s professional development or the objectives of the IPS training framework. After recording the Centre’s submissions regarding the progress of the course, the Supreme Court disposed of the petition.
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The Court also recorded the Centre’s statement that it would withdraw its pending writ petition before the Delhi High Court, which had challenged the interim order passed by the CAT in Sengar’s favour.
Earlier Hearings: Supreme Court Questioned the 1993 MHA Policy
Although the Court declined immediate relief on practical grounds, the proceedings assume significance because of the strong observations made by the Bench during earlier hearings regarding the legality of the 1993 Office Memorandum. The policy requires that an IPS probationer who becomes pregnant during training must discontinue the programme immediately and resume it only one year after childbirth.
During previous hearings, the Bench questioned whether such a blanket rule could continue to operate without considering the medical fitness of individual officers. The Court had observed,
“This is a beneficial provision under law for protecting women and not to take away the right to undergo training if they are fit for it,”
The Bench had further questioned the rationale behind preventing a medically fit officer from undergoing training merely because of the existence of the Office Memorandum. The judges also noted that post-pregnancy recovery differs from woman to woman.
According to the Court, while some women may be physically capable of resuming official duties within a few months after childbirth, others may legitimately require more time. Therefore, the Court indicated that decisions concerning maternity-related interruptions should ideally be based on individual medical assessment rather than a rigid, one-size-fits-all policy.
Although the Supreme Court declined interim relief due to the advanced stage of the current training programme, its observations questioning the continued validity of the 1993 policy have brought renewed attention to the balance between administrative regulations and constitutional protections for women officers in public service. The CAT will now examine the matter on its merits, while the broader legal challenge to the maternity policy is expected to have significant implications for women serving in the Indian Police Service.
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