Cadre Allocation Cannot Be Kept Fluid for Decades: Supreme Court Rejects IPS Officer’s Claim for Re-allocation to Rajasthan After Two-Decade Delay

"Finality must attach to cadre allocation – allowing belated claims would open a Pandora’s box and destabilize entire system": Supreme Court dismisses IPS officer’s plea for insider vacancy in Rajasthan cadre

In a firm reiteration of the doctrine of finality in civil services cadre allocation, the Supreme Court dismissed an appeal filed by Rupesh Kumar Meena, an IPS officer of the 2004 batch, seeking re-allocation from the Tamil Nadu cadre to the Rajasthan cadre against an 'insider' vacancy. The Court held that once cadre allocation is made in accordance with merit and rules, it attains finality, and any attempt to reopen it years later would create a cascading effect detrimental to the integrity and certainty of the All India Services.

Bench of Justice Rajesh Bindal and Justice Atul S. Chandurkar upheld the decisions of the Central Administrative Tribunal and the Rajasthan High Court, both of which had rejected the appellant’s plea on grounds of delay, lack of legal entitlement, and administrative finality.

"Junior Candidate Cannot Claim Right to Insider Vacancy When Senior Declines": Court Rejects Notion of Automatic Succession in Cadre Allocation

The case arose from the appellant’s claim that an ‘insider’ IPS vacancy for Rajasthan in the 2004 Civil Services Examination batch should have been offered to him, as two candidates senior to him in the ST category merit list—Rishikesh Meena and Rajesh Kumar—had not taken up the slot. Rishikesh Meena, already serving in the IPS from the 2003 batch, had not accepted the 2004 Rajasthan insider vacancy to avoid a loss of seniority. Rajesh Kumar, next in merit, secured a favourable order from the Tribunal in 2008 but ultimately joined the IAS during pendency of the government’s writ petition and did not pursue the IPS post.

It was only in 2010—six years after his batch selection—that Rupesh Kumar Meena staked his claim for the Rajasthan cadre, citing the non-acceptance of the insider vacancy by his seniors. The Ministry of Home Affairs rejected this claim, leading to litigation before the Tribunal and subsequently the High Court.

Rejecting the appeal, the Supreme Court held:

“It is not in dispute that the appellant was not the next candidate in the order of merit to be offered the ‘insider’ vacancy... Such a process cannot be adopted. It will result in the process of allocation or change of cadres fluid for all times to come.” [Para 12]

"Vacancy Once Offered Stands Consumed": Supreme Court Endorses Centre’s Stand on Insider Vacancies

The Court accepted the Union of India’s argument that once an insider vacancy is offered and allocation made—whether accepted or not—it stands consumed and cannot be reopened for subsequent candidates. The Bench rejected the notion that the appellant acquired any vested or automatic right merely because two seniors declined the position.

“No material has been produced to show that the aforesaid ‘insider’ vacancy for the year 2004 was still lying vacant for the period of more than 20 years that have passed.” [Para 12]

The Court also warned against the chain reaction that could follow if such claims are entertained:

“Shifting of the appellant from Tamil Nadu cadre to Rajasthan cadre will create a vacancy in the Tamil Nadu cadre for the year 2004… Allocation of cadre will never be final and it will remain fluid for all times to come, leading to a kind of chain reaction.” [Para 4]

The finality of cadre allocation, the Court emphasized, is essential for the stability and administrative coherence of the All India Services.

Delay and Laches: Court Rejects Excuse of Waiting for Senior’s Case to End

The appellant’s explanation that he raised his claim only after Rajesh Kumar’s case became infructuous in 2010 did not impress the Court. Noting that six years had elapsed since the cadre allocation, the Court ruled that such delay was fatal.

“Cadre allocation cannot be kept pending for years together for change, in the manner suggested by the appellant.” [Para 4]

The Court distinguished the case from that of Rajesh Kumar, noting that even his claim was ultimately rendered ineffective, and the High Court had clearly stated that the Tribunal’s order in his favour should not be treated as a precedent.

No Illegality in Original Allocation: Tamil Nadu Cadre Was Lawfully Allotted

The Court clarified that the appellant had no grievance against the initial cadre allocation itself, which was made strictly in accordance with merit and the applicable rules. His claim was not based on any illegality or violation, but a post facto expectation of vacancy availability due to non-joining of others.

“It is not a case where the allegation of the appellant is regarding any illegality committed by the Ministry of Home Affairs... Finality has to be attached to the process of selection.” [Para 11–12]

No Relief Possible After Two Decades

In view of the inordinate delay, lack of entitlement, and the critical need for finality, the Supreme Court found no merit in the appeals and dismissed them:

“We do not find any merit in the present appeals and same are accordingly dismissed.” [Para 13]

The judgment sends a clear message that cadre allocations made under the All India Services framework cannot be reopened at the behest of junior candidates years or decades later, especially in the absence of a legal error or continuing vacancy.

Date of Decision: February 4, 2026