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2026 Supreme(Online)(Mad) 29709

IN THE HIGH COURT OF JUDICATURE AT MADRAS
MUMMINENI SUDHEER KUMAR, J
M.C.Sheela Evanjalin – Appellant
Versus
The Commissioner of Municipal Administration – Respondent
W.M.P.(MD) Nos.7204 & 7207 of 2026



Advocates:
For the Appellants/Petitioners: Mr.A.Thirumoorthy
For the Respondents:Mr.V.Om Prakash Government Advocate for R1 & R2, Mr.M.Raja Rajan Standing Counsel for R3

Internal work adjustments between inter-transferable posts like Accountant and Assistant within same office are not transfers requiring competent authority under service rules.

Headnote:Under Rule 222 of the Tamil Nadu Urban Local Bodies Rules, 2023, the Director of Municipal Administration is competent for transfers of Accountant posts, while Regional Directors handle certain junior roles. Petitioner, promoted from Revenue Assistant to Revenue Inspector and transferred to Accountant (Class-V), challenged an internal work adjustment by Puliangudi Municipality reassigning her to Assistant duties. Court found posts of Accountant, Assistant, and Revenue Inspector inter-transferable per Rule 219, holding the adjustment as internal, not a transfer by incompetent authority. Issues framed: whether impugned order constitutes transfer attracting Rule 222 and prejudices service conditions. Court reasoned internal adjustments within same office do not require higher authority approval, no prejudice caused, and interfering would affect third party not impleaded. Writ petition dismissed at admission stage, no costs.

Table of Content
1. petition challenges internal work adjustment as unauthorized transfer. (Para 2)
2. petitioner argues order is transfer by incompetent authority under rule 222. (Para 3)
3. accountant, assistant, revenue inspector posts inter-transferable per rule 219. (Para 4 , 5)
4. internal work adjustment not transfer; no prejudice to service conditions. (Para 6 , 7)
5. writ dismissed; third party not impleaded. (Para 8)

O R D E R

Heard Mr.A.Thirumoorthy, learned counsel for the petitioner, Mr.V.Om Prakash, learned Government Advocate, who takes notice for the respondents 1 & 2 and Mr.M.Raja Rajan, learned Standing Counsel, who takes notice for the third respondent.

2. This writ petition has been filed aggrieved by the proceedings bearing Na.Ka.No.02/2026/C.1, dated 09.02.2026, issued by the third respondent, whereby an internal work adjustment has been done by the third respondent within the same Municipality requiring the petitioner to perform the works of free meals, travelling allowances, provident fund, census, election work, maintenance of registers and records of town planning audit instead of holding the post of Accountant and requiring one Mr.S.Selvakumar to work as an Accountant and as Manager (in-charge)

3. According to the learned counsel for the petitioner, the impugned order is an order of transfer and the third respondent is not the competent authority to pass the impugned transfer order. He also placed reliance on Rule 222 of the Tamil Nadu Urban Local Bodies Rules, 2023. The said rule prescribes the Director of Municipal Administration as the competent authority for transfer and postings for any post in the service. In respect of the posts of Junior Assistant, Revenue Assistant, Typist and Record Clerk, the Regional Director shall be competent to effect transfer and postings within the Region.

4. As seen from Rule 219 of the Tamil Nadu Urban Local Bodies Rules, 2023, which provides for method of appointment and qualification, the post of Accountant can be filled in by transfer from among the holders of the post of Assistant. The posts of Assistant and Revenue Inspector can be filled in by promotion from among the holders of the posts of Junior Assistant, Typist and Revenue Assistant. So also the post of Revenue Inspector can also be filled in by transfer from among the holders of the post of Assistant. Thus, it is evident that the feeder categories for the posts of Assistant and Revenue Inspector are one and the same. The posts of Revenue Inspector and Assistant are inter-transferable. So also, the posts of Accountant and Assistant are also inter-transferable. The petitioner herein, who was initially appointed as Revenue Assistant, was subsequently appointed by promotion to the post of Revenue Inspector and while holding the post of Revenue Inspector at Rajapalayam Municipality, she was transferred to the post of Accountant (Grade-V) at Puliangudi Municipality through the proceedings bearing Na.Ka.No.986/2023/K.2, dated 18.10.2024, by the first respondent. While holding the post of Accountant in the third respondent Municipality, the petitioner is now required to discharge the functions of the post of Assistant through the impugned proceedings by the third respondent herein. Therefore, as contended by the petitioner, the same cannot be said to be downgrading her status, in any manner.

5. Further, from the proceedings dated 18.10.2024 issued by the first respondent, it is evident that the posts of Revenue Inspector, Assistant and Accountant are inter-transferable. As the said transfers, that were effected through the proceedings dated 18.10.2024, are from one Municipality to other, the said proceedings were issued by the Director of Municipal Administration. Whereas, in the instant case, it is only a case of work adjustment, but not a transfer.

6. As already noted above, the posts of Accountant and Assistant are inter-transferable. Once it is found that the said posts are inter- transferable, the work adjustments

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