Periodical Transfer Guidelines | RPF Personnel Cannot Be Repeatedly Transferred Under Clause D(v) Of Ext.P5 Once Mandatory Tenure Is Served: Kerala High Court

"Having transferred the petitioner invoking Clause D(v) of Ext.P5 to Chengannur, they cannot again rely on the said Clause to transfer him again from Thiruvananthapuram to Chennai." Kerala High Court, in a significant ruling dated October 5, 2026, held that once an employee of the Railway Protection Force (RPF) has been transferred in compliance with the mandatory periodical transfer guidelines for completing the prescribed tenure, the authorities cannot invoke the same clause to justify a subsequent transfer from the same station.

A bench of Justice Viju Abraham observed that the purpose of the regulation is fulfilled once the staff has been rotated out upon completing the required years of service.

The petitioner, a Sub-Inspector in the RPF, had completed 15 years of broken service in the Thiruvananthapuram division and was consequently transferred to Chengannur in 2024. Following a promotion in 2026, he was posted back to Thiruvananthapuram. However, the authorities subsequently ordered his transfer to Chennai, citing Clause D(v) of the transfer guidelines, which mandates transfers for personnel who have completed 10 years at a stretch or 15 years in broken spells at a station.

The primary legal issue before the court was whether the RPF authorities could repeatedly invoke Clause D(v) of the transfer guidelines to transfer an employee from a station where they had already been relocated following a previous application of that very same clause. The court was also called upon to determine if a promotion-related posting creates a new cycle of mandatory periodical transfer eligibility.

Court Rejects Mechanical Application of Transfer Policy

The court examined the scope of Clause D(v) of the transfer guidelines, which stipulates that RPF staff completing 10 years at a stretch or 15 years of broken service at a station must be transferred out of that city or town. The respondents argued that the petitioner’s return to Thiruvananthapuram upon promotion did not grant him immunity from future transfers and that he remained subject to the periodical transfer policy.

Clause Cannot Be Used To Transfer An Already Transferred Employee

The court found significant force in the petitioner's argument that the mandate of Clause D(v) had already been exhausted in 2024. By transferring the petitioner out of Thiruvananthapuram to Chengannur in 2024, the department had already achieved the administrative objective of the periodical transfer policy. Relying on this same provision to justify a second transfer from the same station was held to be legally untenable.

"Having transferred the petitioner invoking Clause D(v) of Ext.P5 to Chengannur, they cannot again rely on the said Clause to transfer him again from Thiruvananthapuram to Chennai as has been done in the present case."

Administrative Recommendations Noted

The court also placed reliance on the recommendation of the Divisional Security Commissioner (the 4th respondent), who had explicitly noted that the petitioner had already undergone the mandatory transfer process. The court concluded that the administrative move to transfer the petitioner again was inconsistent with the department’s own previously applied guidelines regarding the completion of tenure.

Consequently, the court interfered with the impugned transfer orders, quashing them to the extent that they sought to relocate the petitioner from Thiruvananthapuram to Chennai. This ruling reinforces the principle that administrative transfer policies must be applied reasonably and cannot be used as a tool for repeated displacement once the underlying objective of the tenure requirement has been satisfied.

Date of Decision: 05 October 2026