Supreme Court Clarifies Rule 2(g) of the 1966 Recruitment Rules: Forest Range Officers Brought within the “State Forest Service” for Promotion to the Indian Forest Service

Introduction

In P. Maruthi Prasada Rao v. State of Andhra Pradesh & Ors. (2025 INSC 1019), the Supreme Court of India revisited a persistent controversy concerning the eligibility of Forest Range Officers (FROs) for promotion to the prestigious Indian Forest Service (IFoS). The Court was required to interpret Rule 2(g) of the Indian Forest Service (Recruitment) Rules, 1966 (the “1966 Recruitment Rules”) and to decide whether “approval” by the Central Government relates to a service or to a post. The appellant, an FRO later promoted as Assistant Conservator of Forests (ACF), had earlier succeeded before the Central Administrative Tribunal (CAT), only to see that success nullified by the High Court of Andhra Pradesh. The Supreme Court has now restored the wider reading adopted by the CAT, while limiting individual relief for the appellant because of delay.

Summary of the Judgment

Key Holding: “Approval” in Rule 2(g)(i) concerns the entire service, not individual posts. Consequently, Class A officers of the Andhra Pradesh Forest Service—including FROs—constitute a “State Forest Service” (SFS) and are eligible to be considered for promotion to the IFoS.
Effect on Appellant: While the legal question is answered in his favour, the appellant obtains only prospective relief. Owing to his delayed representation and the presence of seven seniors above him, he cannot claim consideration in earlier selection years.
Operative Directions:
- The impugned High Court judgment is set aside.
- Whenever a fresh selection process is initiated, FROs must be placed in the zone of consideration for promotion to the IFoS.

Analysis

A. Precedents Cited

Gopal Singh v. State Cadre Forest Officer's Association, (2007) 9 SCC 369 – Interpreted Rule 2(g)(ii). The Supreme Court notes that clause (ii) stands deleted and is therefore inapposite to the present dispute.
K. Shailendra Moses v. State of Telangana, WP No. 23856/2016 (Telangana HC, 2021) – Relied on by the High Court to deny FRO eligibility; overruled implicitly to the extent of conflict.
P.S. Sadasivaswamy v. State of Tamil Nadu, (1975) 1 SCC 152 – Cited to explain why courts should not grant relief where an employee sleeps over his rights; used to deny retrospective consideration to the appellant.

B. Legal Reasoning

Textual Reading of Rule 2(g): After the omission of clause (ii), the definition is confined to clause (i): “any such service in a State, being a service connected with forestry and the members thereof having gazetted status, as the Central Government may, in consultation with the State Government, approve for the purpose of these rules.” The Court stresses the phrase “any such service” to hold that approval attaches to the service in toto rather than to component posts.
Gazetted Status Requirement Satisfied: Rule 2 of the Andhra Pradesh Forest Service Rules, 1997 places FROs within Class A gazetted categories. Hence they meet the twin criteria: (1) service connected with forestry, and (2) gazetted status.
Implied Central Approval: Although no explicit notification was produced, the Union’s counsel conceded that past practice and the inclusion of similar services in other States indicates an implied approval. The Court refuses to defeat legitimate expectations on an “absence of paperwork” when the statutory intention is clear.
Prospective vs. Retrospective Relief: Applying Sadasivaswamy, the Court deprecates stale claims. The appellant sought relief only in 2021 though his right accrued in 2014. Granting retrospective seniority would unsettle settled selections and unfairly leapfrog seniors.

C. Impact on Future Jurisprudence and Administration

Nationwide Ripple: Several States maintain Forest Range Officers or equivalent cadres that have long felt excluded from IFoS promotion. The judgment will embolden similar claims provided the cadre has gazetted status.
Harmonisation of Rules: State Governments may now proactively seek or record Central approval of their forest services to avoid litigation.
Wider Talent Pool: UPSC Selection Committees must account for a larger cohort, changing the dynamics of merit and seniority in emerging select lists.
Limitation Principle Reaffirmed: Even when a declaration of law favours employees, personal relief can be curtailed where delay is inordinate, preserving administrative certainty.

Complex Concepts Simplified

State Forest Service (SFS): A State-level cadre of officers dealing with forestry, drawn from various ranks, analogous to a State Civil Service.
Gazetted Status: Posts notified in the Gazette of India or a State Gazette; holders can attest documents and usually enjoy supervisory powers.
Select List/Zonal Consideration: UPSC-constituted list from which promotions are made. Only officers within thrice the number of vacancies and who satisfy minimum service requirements are “within the zone.”
Substantive Appointment: A permanent, confirmed appointment (as opposed to officiating or temporary).
Implied Approval: Where formal documentation is missing, the Court may infer approval from consistent governmental conduct and statutory context.

Conclusion

The Supreme Court’s decision in Maruthi Prasada Rao settles a key point that has vexed forest administration for decades: Rule 2(g)(i) turns on services, not posts. Because the Andhra Pradesh Forest Service is a gazetted, forestry-related cadre, its members—including Forest Range Officers—are in principle entitled to be considered for elevation to the Indian Forest Service. At the same time, the Court signals that rights must be pursued diligently; delay can cost tangible benefits even after one wins the legal war. The precedent thus simultaneously expands opportunity and reinforces discipline in public-service litigation.