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31 Oct 2025, 09:25 AM
The Supreme Court dismissed a review petitio filed by the Union Government seeking reconsideration of its judgment dated May 23, 2025, which had held that the Central Armed Police Forces (CAPFs) are part of the Organised Group-A Services (OGAS) for all cadre-related matters.
In that judgment, the Court had also directed that the number of posts filled through deputation of IPS officers in each CAPF up to the Senior Administrative Grade (SAG) level should be gradually reduced over a period of time to ensure that CAPF officers have better chances of promotion.
A bench of Justice Surya Kant and Justice Ujjal Bhuyan rejected the review petition holding, “We have carefully gone through the contents of the Review Petition and the papers appended therewith and are satisfied that no case for review of the judgment dated 23.05.2025 is made out. The Review Petition is, accordingly, dismissed.”
The judgment under review had directed the Central Government to complete the cadre review of all CAPFs and amend the recruitment rules of each force in line with the Department of Personnel and Training's Office Memorandum dated July 12, 2019, which recognised CAPFs as OGAS.
The Court had clarified that CAPFs must be treated as OGAS not only for the purpose of granting Non-Functional Financial Upgradation (NFFU) but also for all cadre-related issues, including cadre review.
The Court had further held that once CAPFs are recognised as OGAS, all benefits available to OGAS should naturally flow to the CAPFs and that “it cannot be that they are granted one benefit and denied the other.”
While acknowledging the grievances of CAPF officers regarding stagnation in promotions due to deputation of Indian Police Service (IPS) officers to higher posts within the forces, the Court observed that such stagnation could adversely affect morale. It directed that the number of deputation posts up to the SAG level be gradually reduced over a period of two years.
The Court had also directed that the cadre review due in 2021 for all CAPFs be completed within six months from the date of judgment and that the Ministry of Home Affairs carry out a review of existing service and recruitment rules of each CAPF after hearing representatives of their cadre officers. The Department of Personnel and Training was directed to take appropriate decisions within three months of receiving reports from the Ministry.
The appeals leading to the May 23 judgment had been filed by Group-A officers from the CRPF, BSF, ITBP, CISF and SSB, seeking recognition of their services as OGAS and corresponding service benefits. They had contended that over 18,000 officers had been litigating the issue since 2009 due to stagnation in promotions and lack of parity in cadre management.
The Union of India had opposed the plea, arguing that deputation of IPS officers was essential for operational coordination with state police forces and that uniformity in recruitment rules across CAPFs was neither intended nor practical.
Case no. – Review Petition (Civil) Diary No. 36887/2025
Case Title – Union Of India & Ors. v. Sanjay Prakash & Ors.