Group-A officers in India’s Central Armed Police Forces (CAPFs) (CRPF, BSF, CISF, ITBP, SSB) have petitioned for “Organised Group‐A” service (OGAS) status to end chronic promotion stagnation caused by heavy IPS deputations. Their grievances stem from long delays – e.g. an Assistant Commandant may wait 6–7 years to become Deputy Commandant and 7–10 more to reach Commandant (colonel rank) – because, they allege, 20–50% of senior posts (DIG/IG) are reserved for IPS officers. In 2019 the Supreme Court (in Harananda) granted CAPF officers the benefit of Non-Functional Financial Upgradation (NFFU) but left open whether CAPFs should be treated as full OGAS. A pivotal DoPT memo of 12 July 2019 had stated that “Group-A Executive Cadres of [the five CAPFs] have been treated as Organised Group A service (OGAS) by this Department for cadre review and other related matters”. CAPF officers claim this meant all OGAS privileges (including 100% promotions up to SAG) should apply, while the MHA historically resisted changes beyond NFFU. This conflict culminated in the May 23, 2025 Supreme Court decision and a July 2025 review petition by the MHA.
Supreme Court Judgment (May 23, 2025)
A Bench of Justices Oka and Justice Bhuyan delivered a landmark verdict in Sanjay Prakash & Ors. v. Union of India (May 23, 2025), addressing multiple CAPF petitions. Its key holdings were:
- Full OGAS Status: The Court held that, in light of the 2019 DoPT OM and prior rulings, CAPF Group-A cadres are OGAS “for all purposes”. It noted that the Government itself had already granted CAPFs NFFU in Harananda and the 2019 OM “abundantly” confirmed OGAS status for cadre matters. “When CAPFs have been declared as OGAS, all benefits available to OGAS should naturally flow to the CAPFs. It cannot be that they are granted one benefit and denied the other,” the Court declared. In other words, financial and promotion benefits accorded to OGAS must apply across the board.
- Cadre Review and Recruitment Rules: The Court directed the overdue CAPF cadre reviews (due since 2021) to be completed within six months. It ordered the MHA/DoPT to amend each CAPF’s recruitment rules to conform to OGAS norms (e.g. 100% promotions up to SAG) within that timeframe. DoPT was instructed to take further action within three months after receiving the review reports. These directions ensure CAPF service rules align with the OGAS classification.
- IPS Deputation Reduction: Balancing CAPF career mobility against security needs, the Court ordered that the number of IPS officers on deputation in each CAPF up to SAG (IG rank) be “progressively reduced… within an outer limit of two years”. This sweeping directive gradually phases out IPS dominance in senior posts. It was aimed at removing “long-standing grievances” of CAPF cadres and increasing cadre participation in leadership.
- Operational Necessity Acknowledged: While enforcing these reforms, the Court acknowledged CAPFs’ critical roles. It explicitly noted that CAPF officers “upholding the security, integrity and sovereignty of the nation” under demanding conditions must not have their sacrifices overlooked. The judgment observed that, even as IPS deputations were policy-driven for coordination, the “great deal of stagnation” from lateral entries “can adversely impact the morale of the forces,” which must be factored into policy.
In sum, the May 23 order affirmed that CAPFs are OGAS in all respects and mandated prompt cadre restructuring. The Court framed its relief in constitutional terms: it implied that denying CAPFs the full OGAS package violated principles of equality and fair opportunity (it cited counsel’s argument that ignoring unified promotion norms breaches Articles 14 and 16). The judgment disposed of the CAPF officers’ appeals, lifting the prior stay on cadre review and crystallizing the cadre reform agenda.
Key Judgment Points (Citings)
- OGAS “for all purposes” – The Court emphasized that the 2019 DoPT OM means CAPFs must be treated as OGAS “for all purposes”. All OGAS benefits (pay, promotions, postings) must follow.
- Aggregate Benefits – It held that once a service is OGAS, one cannot grant some benefits (e.g. NFFU) and withhold others.
- Cadre Review in 6 Months – A comprehensive review of CAPF cadres and amendment of service rules was ordered within six months.
- Deputation Cutback – IPS posts up to IG rank were to be “progressively reduced” over ~2 years, aiming to open those slots to CAPF officers.
- Morale and Recognition – The Court repeatedly noted CAPFs’ dedicated service and difficult conditions, and warned that persistent stagnation “can adversely impact morale”. It explicitly sought to factor these concerns into CAPF policy.
MHA Review Petition (July 2025)
On July 11, 2025 the Ministry of Home Affairs filed a review petition asking the Supreme Court to reconsider its May 23 directives. The Government’s petition raises several objections:
- Operational Concerns: The MHA stresses that IPS officers are essential to CAPF effectiveness. It argues that CAPFs are “federal” armed forces which routinely operate in all states, and IPS deputations ensure seamless coordination with state governments and police forces. The petition notes IPS (as an All-India Service) play a “crucial” role in bridging Centre–State relations, especially in internal security operations. Thus, phasing out IPS posts too quickly could disrupt the forces’ readiness.
- Structural Distinctions: MHA contends that CAPFs differ fundamentally from civilian OGAS. Each CAPF has unique functional mandates (border patrol, industrial security, etc.), so uniform cadre structures are impractical. The petition argues it is “for the cadre controlling authority (MHA) to decide appropriate structure” – for example, CAPFs have special allowances and roles not found in other services. Imposing all six OGAS attributes indiscriminately, the MHA says, would undermine these tailored structures.
- Policy and Cadre Review Process: The Government emphasizes that recruitment rules and cadre composition are administrative (executive/legislative) matters. It argued that implementing the SC’s broad changes via court order would pre-empt the statutory cadre review process. The MHA notes that a CAPF cadre review is underway (or stayed) and must be allowed due course. It implied that the reforms directed by the Court exceed its jurisdiction, touching on executive policy (e.g. how many deputation posts to authorize).
- Continuing Appointments: Practically, the MHA has not frozen IPS deputations. Indeed, since the judgment it continued appointing senior IPS officers to CAPF commands – at least eight new senior appointments (Commandant to IG) were made after May 23. The review plea highlights these appointments as evidence of “operational necessity” and argues against unwinding them abruptly.
- Implicit Financial/Organizational Costs: While not explicitly detailed in open sources, the Government’s stance suggests concerns about the financial and administrative impact of rapid promotions. Rewriting recruitment rules to allow 100% promotions to SAG, for instance, would significantly expand the wage bill (by accelerating promotions and pensions for CAPF officers) and strain budgets. The petition likely warns of such budgetary burdens and manpower disruptions, though such arguments are less documented publicly.
In sum, the review petition urges moderation: it seeks to retain the IPS share of senior CAPF posts (arguing continuity is vital for security) and to delay or dilute the Court’s aggressive restructuring. It frames the SC’s orders as potentially impractical, stressing CAPF forces’ special status, and insists that any reforms be phased through normal procedures.
CAPF Officers’ Grievances
CAPF officers have long catalogued multiple service grievances, many of which the Court acknowledged:
- Promotion Stagnation: Senior CAPF cadres complain that their promotional pipeline is jammed. For example, a senior police veteran observed it takes about 25 years for a CAPF officer to reach Commandant, when in other Group-A services it should take ~13 years. The reasons are twofold: (1) a pyramidal cadre structure with few top posts, and (2) a large fraction of those posts reserved for outsiders. CAPF petitioners pointed out that the higher one goes, the higher the percentage of posts filled by IPS deputation. The Supreme Court described this as “a great deal of stagnation” and found that such career stagnation “can adversely impact the morale of the forces”.
- Deputation Bottlenecks: Currently, roughly half of IG-level positions and about 20% of DIG-level posts in each CAPF are earmarked for IPS officers. Because promotions up to SAG (IG rank) are structured to occur “within the service” for OGAS, each IPS entrant effectively blocks a CAPF officer’s path. The Court noted CAPF officers’ grievance “that because of lateral entry into the higher grades of the respective CAPFs, they are unable to get their timely promotion”. As one CAPF official put it, reserving so many senior slots for IPS “hamper[s]” CAPF officers’ prospects. This bottleneck was a central complaint in the petitions.
- Morale and Recognition: CAPF personnel stressed the vital nature of their work – guarding borders, counter-insurgency, election security, etc. They point to their “dedicated service” under hostile conditions and even note officers killed in the line of duty. The Court echoed this: CAPFs’ role in “upholding the security, integrity and sovereignty of the nation” must be “factored in” when considering their career demands. Officers have campaigned that full OGAS status will honor their sacrifices and restore “dignity and equity” to their career path.
- Functional Parity: The CAPF lawyers also argued that parity with other paramilitary services (like the Railway Police RPF, already OGAS) is constitutionally required. They cited Article 14/16: once the Sixth Pay Commission’s uniform norms were accepted for Group-A services, treating CAPFs differently breaches equality. The Supreme Court’s willingness to apply equal OGAS treatment (and to mandate parity in promotions) reflects these constitutional arguments.
In brief, CAPF officers’ long-standing issues – delayed promotions, blocked vacancies, low morale – underpinned the litigation. The Court’s order explicitly addresses each: acknowledging stagnation, ordering rule changes for internal promotions, and trimming outsider deputations.
Constitutional Aspects
The CAPF side anchored much of its case in Articles 14 and 16 of the Constitution (equality and equality of opportunity). Counsel argued that the Sixth CPC’s accepted recommendation of identical promotional criteria for all OGAS means any deviation is discriminatory. By accepting CPC parity, the Government was “bound to implement” it for all services, failing which it breaches Article 14/16. The Supreme Court agreed that denying CAPF cadres the same OGAS perks as others (after formally accepting them into OGAS) violated equal protection principles. It observed that CAPF officers of equal merit were being treated unequally purely due to historical recruitment differences. Thus, the judgment can be seen as enforcing constitutional guarantees: CAPF officers now have a clear claim to the same career progression rights enjoyed by their counterparts in other Group-A services.
Stakeholder Reactions
- CAPF Leadership/Officers: While formal press statements by active CAPF DGs are rare, the judgement has been widely welcomed by CAPF circles. A senior CAPF official told Indian Masterminds that the review petition could have “far-reaching consequences” on cadre rules, underscoring how momentous the ruling was. Cadre associations and social media campaigns (#GoBackIPS) have praised the decision as vindication of their long struggle. Officers expect faster promotions and a voice in force management.
- IPS Community: Many IPS officers are anxious about losing CAPF posts. Although no public IPS leadership comment on the 2025 verdict is on record, earlier coverage shows IPS advocates stressing the importance of deputation. The Economic Times reports the Home Ministry argued IPS are an “important” part of the CAPF hierarchy and “essential” for state-level coordination. The retired IPS leadership in 2019 secured a court clarification that IPS deputation rights would not automatically end with OGAS status, so some IPS feel the 2025 order strikes a balance. Nevertheless, some IPS analysts privately caution that the judgement undervalues state-CAPF synergy.
- Defence/Policy Analysts: Security experts note the need for balance. Retired special forces chief O.P. Rawat commented that CAPFs do need more officer-level continuity, but also that experience “on the ground” is critical. He said deploying senior IPS in CAPFs helps leadership understand complex ground situations, and any reform must “balance the two” (career and operational needs). Other analysts point out that CAPFs’ dual civil-military nature was a factor: unlike Army units, CAPFs interface heavily with civilian agencies. Reduction of IPS (who belong to Police cadres) could hamper election duties or Naxal operations unless new liaison mechanisms emerge.
- Government: The MHA (through the Solicitor General) defended its position in court and filed the review. In open filings (see Economic Times and Indian Kanoon records), the Government has underscored CAPFs’ unique functional requirements, suggesting each CAPF must tailor its career structure. No official public denial of the Court’s orders was issued, but the rapid push of IPS appointments after the verdict (e.g. senior commanders in CRPF/CISF/SSB) signaled reluctance to implement the reduction unilaterally.
Implications and Outlook
- For CAPF Personnel: If fully implemented, the ruling vastly improves career prospects. CAPF officers can now expect cadre reviews granting 100% promotions up to IG level, better pay progression, and eventual end to service-wide deputation ceilings. Morale should rise as career ceilings are lifted. CAPFs will also likely expand internal training programs to prepare officers for leadership roles now reserved to the cadre.
- For IPS Careers: IPS officers will face a gradual decline in Central deputation slots within CAPFs. This may shift senior IPS attention back to state policing or to other central forces (CBI, IB, etc.). The cutback need not end IPS–CAPF ties: remaining IPS officers may serve in advisory or liaison billets. IPS recruitment and training may eventually adapt (some analysts have speculated about creating a parallel CAPF police cadre, though no formal proposal exists).
- Inter-agency Coordination: The reduction of IPS in CAPFs poses questions for federal-state security synergy. Historically, IPS officers on deputation have served as natural links to state police hierarchies. With fewer IPS in CAPFs, the MHA and states may need new protocols (e.g. joint task forces, CAPF officers attending police courses) to maintain coordination. The SC itself noted these concerns when it said the reduction must balance “service mobility” with “operational/functional requirement of the forces”. The coming cadre reviews will have to institutionalize such balance.
- Administrative and Financial Effects: The Government must now draft and pass new service rules for each CAPF. This will involve negotiating allowances, rank structures, and promotion pipelines in consultation with cadres. Financially, implementing OGAS fully implies a higher budget for CAPF payrolls (due to accelerated promotions and pensions). The precise cost impact will be debated in the ensuing cadre reviews. MHA may also re-examine the formula for sanctioned posts (it could propose creating more posts so promotions do not bottleneck, or gradually increase intake of direct recruits).
- Legal/Policy Precedents: This episode sets significant precedents. Legally, it affirms that an OGAS classification (once accepted by government and court) carries a bundle of rights enforceable in court. It also shows the courts willing to issue broad mandamus on administrative reform when fundamental equality is at stake. Practically, unless the review petition succeeds, agencies now have strict timelines: cadre reviews by Nov 2025, recruitment rules aligned, and a two-year horizon for reducing IPS posts.
In summary, the Supreme Court’s May 2025 decision marks a decisive victory for CAPF officers seeking institutional equity. The MHA’s review plea highlights genuine governance challenges, but its success would simply pause or attenuate reforms rather than negate CAPFs’ OGAS status. The coming months will determine how India’s security forces balance merit-based promotions with the complex demands of internal security.
Sources:
https://indiankanoon.org/doc/159494620/#:~:text=,and%20other%20related%20matters%20accordingly
api.sci.gov
