The Supreme Court's Stance on Forest Range Officers as "State Forest Service"


22-August-2025 Civil Appeals >> Civil & Consumer Law  

In the case of a Forest Range Officer (FRO) from Andhra Pradesh, the Supreme Court addressed a legal dispute over promotion to the Indian Forest Service (IFoS). The officer, who had been an FRO since 2006, was promoted to Assistant Conservator of Forests (ACF) in 2020. He sought to be considered for promotion to the IFoS, arguing that FROs should be classified as "State Forest Service" officers under the relevant rules.

The Central Administrative Tribunal (Tribunal) initially ruled in favor of the officer, directing the state to consider FROs as part of the State Forest Service and to evaluate his eligibility for promotion to the IFoS. However, the High Court of Andhra Pradesh reversed this decision, stating that the FRO service was not an approved "State Forest Service" by the Central Government and thus, FROs were not eligible for promotion to the IFoS.

 
 

The Supreme Court examined Rule 2(g) of the Indian Forest Service (Recruitment) Rules, 1966, which defines "State Forest Service." The court found that the rule requires Central Government approval for any state service connected with forestry whose members have gazetted status. After reviewing the Andhra Pradesh Forest Service Rules, 1997, the court concluded that the Andhra Pradesh Forest Service, which includes FROs, has members with gazetted status. The court declared that the approval mentioned in the rule applies to the service as a whole, not individual posts. It also inferred an "implied approval" of the Andhra Pradesh Forest Service by the Central Government.

As a result, the Supreme Court ruled that members of the Andhra Pradesh Forest Service, including FROs, are eligible for promotion to the IFoS, provided they meet the substantive appointment and service length requirements.

However, the court denied the appellant's request for retroactive consideration for promotion, noting that he had waited too long (from 2014 to 2021) to raise his grievance. The court stated that such "stale claims" should not be entertained, especially when it could allow him to jump ahead of his seniors.

Ultimately, the Supreme Court set aside the High Court's order and directed that in all future recruitment drives for the IFoS, the Andhra Pradesh Forest Service must be treated as a "State Forest Service," and FROs must be considered eligible for promotion.


Section 19, Administrative Tribunals Act - 1985  

Administrative Tribunals Act, 1985