departmental action is so serious a proceeding that keeping in view its adverse effects on the livelihood and reputation of the employee, the Supreme Court observed that even Constitution of India, 1950 (COI) – Article 21 which guarantees right to ife with its human diginity, gets attracted if a fair procedure is not adopted.

In case the transfer if also found to be issued as a measure of punitive measure or colourable exercise of powers or as an oblique motive, they also fall under the category of illegal or arbitrary transfers and can be challenged. Frequent and unscheduled transfers also fall under this category and can be challenged before the court of law.