SANJAY PRAKASH & ORS. versus UNION OF INDIA & ORS.

SANJAY PRAKASH & ORS. versus UNION OF INDIA & ORS.

The Court held that the CAPFs (CRPF, BSF, CISF, ITBP, SSB) are Organized Group-A Services for all purposes; the Government (DoPT) has accepted this status by OM dated 12.07.2019; consequently, benefits available to OGAS (including NFFU already granted and NFSG where applicable) should flow to CAPFs and the Ministry of Home Affairs must undertake cadre review and review/amendment of service rules/recruitment rules and progressively reduce deputation posts up to SAG within specified timelines.

Parties
Appellants: Sanjay Prakash & Ors.; Respondents: Union of India & Ors.
Jurisdiction
India
Judgment Date
23 May 2025
Procedural Posture
Civil Appeal / Appeal From Judgment and Order of the High Court of Delhi Dated 27.07.2020
Outcome
Appeals disposed of
Legal Topics
Organized Group a Service (ogas), Non Functional Financial Upgradation (nffu), Cadre Review, Deputation, Recruitment Rules, Promotion and Stagnation
Administrative Law Service Law Constitutional Law Organized Group a Service (ogas) Non Functional Financial Upgradation (nffu) Cadre Review Deputation Recruitment Rules +1 more

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Parties

Sanjay Prakash & Ors.

Appellants

Union of India & Ors.

Respondents

Procedural Posture

Civil Appeal / Appeal From Judgment and Order of the High Court of Delhi Dated 27.07.2020

Legal Issues

  1. 1 Whether the Central Armed Police Forces (CRPF, BSF, SSB, ITBP, CISF) are Organized Group-A Services (OGAS) for all purposes
  2. 2 Whether benefits available to OGAS (including NFFU, NFSG and cadre/recruitment rule restructuring) must be extended to CAPFs
  3. 3 Whether deputation/lateral entry of IPS officers into CAPF cadres up to SAG level must be eliminated or reduced and whether cadre review/service rule amendments should be directed

Ratio Decidendi

The Court held that the CAPFs (CRPF, BSF, CISF, ITBP, SSB) are Organized Group-A Services for all purposes; the Government (DoPT) has accepted this status by OM dated 12.07.2019; consequently, benefits available to OGAS (including NFFU already granted and NFSG where applicable) should flow to CAPFs and the Ministry of Home Affairs must undertake cadre review and review/amendment of service rules/recruitment rules and progressively reduce deputation posts up to SAG within specified timelines.

Court Disposition

Appeals disposed of

Orders

  • Cadre review in all CAPFs which was due in 2021 to be carried out within six months from today
  • Ministry of Home Affairs to give effect to DoPT OM dated 12.07.2019 and undertake review of existing service rules/recruitment rules of each CAPF, with representatives of cadre officers given opportunity of being heard