The court held that compelling an officer to complete Basic Jungle Camp Training after prior illness and advanced training is unreasonable, directing consideration for probation confirmation based on actual training completed.

JUDGMENT : 

SHALINDER KAUR, J.

1. By way of present petition under Article 226 of the Constitution of India, the petitioner, who is currently serving as an Assistant Commandant in the Central Reserve Police Force (CRPF), has approached this Court seeking the following reliefs:-

“a) Issue an appropriate writ/order/direction in the nature of Mandamus, or any other writ, to set aside the Impugned Office Order dated 31.08.2022 issued by DIG (pers),CRPF, Selo Message dated 25.04.2022 issued by Digcent (pers), Impugned Signal dated 06.04.2022 passed by the CRPF Academy Gurugram, Signal dated 14.12.2021 issued by CRPF ACADEMY, impugned Signal dated 16.08.2021 issued by 229 BN CRPF, 31.01.2020 issued by CRPF ACADEMY GURUGRAM, impugned Signal dated 17.12.2021 issued by 229 Bn, Signal 04.10.2021 issued by 229 Bn. 

b) Issue a writ/order/direction in the nature of mandamus directing the respondent authorities to exempt the petitioner from undergoing the jungle camp training and to process the final assessment report for fixing of inter-se-seniority among the batch.”

2. To give a brief overview of the dispute, it may be noted that the petitioner joined the CRPF as an Assistant Commandant on 18.11.2017 and was undergoing Basic Training with the 50^th  Batch of the Directly Appointed Gazetted Officers (DAGOs). The basic training comprised of a month-long Jungle training module, which consisted of fifteen days of Jungle Camp, seven days of Survival Module, and four days of Field Firing & Battle Inoculation Module. While undergoing the Jungle training module with her batch, and after attending four days of Jungle Camp training, the petitioner contracted chicken pox on 27.10.2018 and was admitted to the CRPF Academy hospital in Gurugram. The petitioner was declared fit to return to duty vide the  Medical Certificate/Fitness to Return Duty Certificate dated 06.11.2018, issued by the Composite Hospital, New Delhi. Subsequent thereto, the petitioner requested the then Inspector General (IG), Academy to allow her to participate in the remaining two Modules, that is, the seven days Survival Module and the four days Field Firing and Battle Inoculation Module, which she successfully completed.

3. After passing out from the Academy on 16.12.2018, the petitioner was posted to 229^th Battalion, Bijapur, Chhattisgarh, a Category – I and Core Special Operation Zone (SOZ) Battalion. She also completed a Counter Insurgency and Anti-Terrorism (CIAT) Course, Sl. No. 23, at the Counter Insurgency and Anti-Terrorism School, Shivpuri, Madhya Pradesh, for the period of 17.01.2019 to 08.03.2019, which is an advance version of Jungle Training.

4. On 08.03.2019, the petitioner was relieved to 229th Bn., after attending the CIAT Course for QAT of LWE. She was granted 15 days leave and was directed to report back after availing the said leave.

5. During this period, while working as an Assistant Commandant with 229^th Bn., CRPF, Bijapur, Chhattisgarh, the petitioner received various Commendation Certificates for her hard work, dedication and for successfully performing her duties. She was awarded the Director General’s (DG) Commendation Certificate, and a Commendation Certificate dated 06.10.2019 by the Office of Director Inspector General of Police (DIGP)(Ops), Dantewada, Chhatisgarh, CRPF.

6. When the petitioner was detailed to undergo the Jungle Camp training with the 51^st batch, on 30.12.2019, she sent a signal to 229^th Bn, requesting for an exemption from said tra