Delhi High Court Dismisses IFS Probationers’ Pleas, Upholds Bar On Appearing In Civil Services Exam During Training
Isabella Mariam
The High Court of Delhi Division Bench of Justice Anil Kshetarpal and Justice Amit Mahajan upheld the bar on Indian Forest Service probationers from appearing in the Civil Services Examination during their probationary training, dismissing a batch of petitions. The petitioners, undergoing training at the Indira Gandhi National Forest Academy, questioned a 23 November 2023 amendment issued by the Union government that prevents trainees from taking the CSE or any other open competitive examination while the training continues, saying it should not apply to those who had joined days earlier. The court said the amendment operates on the ongoing training period from its start date and found no illegality or arbitrariness in the refusal of permission to sit the examination while on training.
The writ petitions arose from a common judgment passed by the Central Administrative Tribunal dismissing original applications filed by probationers of the Indian Forest Service. The petitioners had been selected through the Indian Forest Service Examination, 2022 and joined probationary training at the Indira Gandhi National Forest Academy on 15 November 2023.
The dispute concerned the applicability of the Indian Forest Service (Probation) Amendment Rules, 2023, notified on 23 November 2023, which reintroduced a prohibition on probationers appearing in the Civil Services Examination or any other open competitive examination during the period of training. The petitioners contended that the amendment could not apply to them as they had joined training prior to its notification and asserted a legitimate expectation based on the rules prevailing at the time of joining.
The respondents maintained that the amendment was prospective, applied uniformly to all probationers undergoing training after its enforcement, and was intended to ensure uninterrupted training and discipline. The Tribunal rejected the challenge, holding that no vested right had accrued to the petitioners. The writ petitions questioned the correctness of that determination under Article 226 of the Constitution of India.
The Court recorded that “the conditions governing their probation and training must, for all purposes, remain frozen as they stood on the date of their appointment” could not be accepted as an absolute proposition. It observed that “service jurisprudence recognises that conditions of service, including those regulating probation and training, are governed by the statutory rules as they stand from time to time.”
Referring to settled principles, the Court stated that “a probationer does not acquire an immutable or vested right to insist that the regulatory framework prevailing on the date of entry into service must continue unchanged throughout the period of probation.” It noted that service conditions are “liable to change in public interest, subject to the requirements of fairness under Article 14 of the Constitution.”
On the nature of the 2023 Amendment, the Court recorded that “the prohibition on appearing in open competitive examinations during training is not alien or newly introduced,” and that the amendment “re-introduced the very prohibition which formed part of the statutory regime governing IFS probation for a substantial period of time.” The Court observed that the amendment “does not, in law, amount to a retrospective deprivation of any accrued or vested right.”
Addressing the argument of retrospectivity, the Court stated that “a statutory rule operates retrospectively only when it is expressly so provided, or when it seeks to alter or take away vested or accrued rights.” It recorded that the amendment “merely regulates the manner in which probationary training is to be undergone from the date of its enforcement onwards.”
On legitimate expectation, the Court observed that “once the competent authority, in exercise of its rule-making power, restored the earlier prohibition… no enforceable expectation could survive contrary to the amended rule.”
The Court also noted that an option had been provided to seek deferment or exemption from training and recorded that “the Petitioners, however, consciously elected to continue with the probationary training… notwithstanding full knowledge of the amended Rule position.”
Regarding the scope of judicial review, the Court recorded that “the writ jurisdiction is supervisory and not appellate in nature,” and reiterated that interference is limited to jurisdictional error, error apparent on the face of the record, or findings based on no evidence.
The Court recorded that “this Court finds no infirmity in the Impugned Order passed by the Tribunal. The Writ Petitions are devoid of merit and are accordingly dismissed. All pending applications also stand closed.”
Advocates Representing the Parties
For the Petitioners: Mr. Shrey Kapoor, Advocate; Mr. Nishit Agrawal, Advocate; Ms. Kanishka Mittal, Advocate; Ms. Deepti Rathi, Advocate
For the Respondents: Ms. Monika Arora, CGSC; Mr. Debasish Mishra, Government Pleader; Mr. Shashank Dixit, CGSC; Mr. Kunal Raj, Advocate; Dr. Monika Arora, CGSC; Mr. Subhrodeep Saha, Advocate; Mr. Prabhat Kumar, Advocate; Ms. Anamika Thaku, Advocate; Mr. Abhinav Verma, Advocate
Case Title: Abhimanyu Singh & Anr. v. Union of India & Ors.
Neutral Citation: 2026: DHC:276-DB
Case Number: W.P.(C) 171/2026 & connected matters
Bench: Justice Anil Kshetrapal, Justice Amit Mahajan
