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CAT Dismisses Interim Relief Plea of IFS Officer Sushanta Kumar Pattnaik in UKPCB Deputation Case

Dehradun: IFS Officer Pattnaik’s Plea for Restoration as UKPCB Member Secretary Dismissed by CAT
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Dehradun: The Central Administrative Tribunal (CAT), Principal Bench, has refused interim relief to IFS officer Sushanta Kumar Pattnaik in his ongoing dispute over deputation as Member Secretary of the Uttarakhand Pollution Control Board (UKPCB).

In its March 17, 2026 order, the Tribunal dismissed Pattnaik’s application, imposed a cost of Rs 10,000, and held that the plea essentially sought final relief at an interim stage. The bench emphasized that earlier interim protections could not be interpreted as restoring his claim, drawing a distinction between quashing an order and merely staying its operation.

Background of the Case

The case arises from Pattnaik’s challenge to his attachment from UKPCB to the office of Chief Conservator of Forests, Uttarakhand, through an order dated January 25, 2024. He sought restoration to the Member Secretary post in pay level 15, citing his appointment order dated April 25, 2023.

Pattnaik argued that the attachment order

  • Preceded the constitution of the local complaints committee,
  • Was not based on findings under the PoSH Act, and
  • Ignored CAT’s earlier orders (January 9, 2025, and December 16, 2025) directing restoration of his status.

State Government’s Stand

The Uttarakhand Government opposed the plea, stating that Pattnaik’s temporary assignment was canceled on January 6, 2026, under Rule 10 of the UKPCB Rules, 2021, allowing removal before term completion due to financial issues or misconduct.

The Tribunal noted that

  • This cancellation was not challenged in the main application,
  • Pattnaik was serving in his parent cadre as Chief Conservator of Forests (Project and Community Forestry), Dehradun, in pay level-14 since April 1, 2025, with no financial loss or demotion.

Tribunal’s Observations

At the interim stage, the CAT upheld the state’s position, stating

  • Pattnaik had no vested statutory right to continue on deputation or choose postings.
  • Citing Supreme Court precedents — State of Haryana vs SN Sharma, State of UP vs Ram Sukhi Devi, and State of UP vs Sandeep Kumar Balmiki — the Tribunal emphasized that final relief cannot be granted through interim orders.
  • The plea was termed a “patent misuse of the court.”

Sushanta Kumar Pattnaik – IFS Officer Profile and Recent Developments

Mr Pattnaik is a senior Indian Forest Service (IFS) officer from the 1991 batch of the Uttarakhand cadre. He has served as the Chief Conservator of Forests in Uttarakhand and, in 2024, was additionally tasked with managing Non-Timber Forest Produce (NTFP).

In early 2024, Pattnaik faced allegations of misconduct and “indecent behaviour” toward a female forest department employee, leading to his removal from the post. The Uttarakhand government initiated a high-level inquiry, during which he was attached to the office of the Principal Chief Conservator of Forests (HoFF).

He entered the IFS after clearing the Civil Services Examination and completed his foundation training at the Lal Bahadur Shastri National Academy of Administration (LBSNAA).

Conclusion

The decision reinforces that deputation postings are at the discretion of the government and that officers cannot claim a right to a specific assignment, particularly at the interim stage. The ruling has significant implications for IFS officers seeking restoration or preferential postings while administrative or disciplinary processes are pending.


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