The Supreme Court affirmed Central Armed Police Forces (CAPFs) as ‘Organized Group-A Services,’ entitling officers to Non-Functional Financial Upgradation. It directed a six-month cadre review and recruitment rule revision. The Court also suggested progressively reducing IPS deputation posts in CAPFs to address officer stagnation and grievances
Facts Of The Case:
The case originated from a long-standing grievance of officers belonging to the Central Armed Police Forces (CAPFs) – including CRPF, BSF, SSB, ITBP, and CISF. These officers sought recognition of their services as ‘Organized Group-A Services’ (OGAS), a crucial classification for ensuring parity with other Group-A services and entitlement to benefits such as Non-Functional Financial Upgradation (NFFU). A primary concern for CAPF officers was career stagnation resulting from the large-scale deputation of Indian Police Service (IPS) officers to higher administrative posts within the CAPFs, which significantly curtailed promotional opportunities for cadre officers. Despite a cadre review being due in 2021, it had not been conducted, intensifying the issues of career progression. Various writ petitions were filed before the High Court of Delhi, challenging the denial of OGAS status, NFFU, and the adverse impact of deputation. The High Court’s judgments on these matters led to the present civil appeals before the Supreme Court of India, which consolidated and heard the common grievances.
Procedural History:
The genesis of this case lies in multiple writ petitions filed before the High Court of Delhi, addressing common grievances of officers within the Central Armed Police Forces. These petitions sought relief regarding the status of CAPFs as Organized Group-A Services, entitlement to Non-Functional Financial Upgradation, and issues stemming from IPS deputation. The High Court of Delhi delivered a common judgment and order on July 27, 2020, disposing of these writ petitions. Aggrieved by the High Court’s decision, several parties subsequently filed civil appeals before the Supreme Court of India. These appeals, sharing identical substantive grievances, were consolidated by the Supreme Court and heard together, culminating in the present common judgment and order.
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Court Observation:
The Supreme Court observed the persistent grievances of Central Armed Police Forces (CAPFs) officers regarding career stagnation and parity. The Court emphasized that recognizing CAPFs as ‘Organized Group-A Services’ (OGAS) is crucial for the morale and career progression of their personnel, making them eligible for benefits like Non-Functional Financial Upgradation (NFFU). A significant observation concerned the adverse impact of the extensive deputation of IPS officers to higher positions within CAPFs, which severely limited promotional opportunities for cadre officers. The Court highlighted the critical need for timely cadre reviews and regular revisions of recruitment rules to address stagnation. Ultimately, the Supreme Court aimed to strike a balance between the operational demands of the forces and the legitimate career aspirations of the dedicated CAPF cadre, acknowledging the long-standing nature of these issues.
Final Decision & Judgement:
The Supreme Court, in its final judgment, affirmed the status of Central Armed Police Forces (CAPFs) as ‘Organized Group-A Services,’ unequivocally entitling their officers to Non-Functional Financial Upgradation. Crucially, the Court directed the Ministry of Home Affairs to complete a comprehensive cadre review for all CAPFs within six months and to simultaneously review existing recruitment rules in compliance with DoPT guidelines. Furthermore, addressing the issue of stagnation, the judgment mandated a progressive reduction of posts earmarked for deputation in CAPFs, up to the Senior Administrative Grade, within an outer limit of two years. This measure aims to enhance the career progression and participation of cadre officers. The interim stay on cadre review was also recalled, and all civil appeals were disposed of in these terms, with no costs awarded.
Case Details:
Case Title: SANJAY PRAKASH & ORS. VERSUS UNION OF INDIA & ORS.
CITATION: 2025 INSC 779
Civil APPEAL No.: 13104 OF 2024
Date Of Judgement:May 23, 2025
Judges/Justice Name: Justice Ujjal Bhuyan & Justice Abhay S. Oka
Download The Judgement Here