Delhi High Court Upholds Bar On IFS Probationers Appearing In Civil Services Exam During Training
Nupur Thapliyal
13 Jan 2026 7:15 PM IST
The Delhi High Court on Tuesday upheld bar on Indian Forest Service (IFS) probationers from appearing in the Civil Services Examination (CSE) during their training period.
A division bench comprising Justice Anil Kshetarpal and Justice Amit Mahajan dismissed a batch of petitions filed by various IFS probationers challenging a 2023 amendment prohibiting them from appearing in the CSE or any other open competitive exam during their probationary training.
The Court upheld the validity of the Indian Forest Service (Probation) Amendment Rules, 2023, which re-introduced a prohibition that had existed earlier but was removed in the year 2017.
The petitioners were selected in the Indian Forest Service Examination, 2022, and joined probationary training at the Indira Gandhi National Forest Academy (IGNFA).
Dismissing the plea, the Bench ruled that the prohibition on appearing in open competitive examinations, including CSE, during training is not alien or newly introduced.
It said that the impugned Amendment restores the original position that probationary training at IGNFA is required to be pursued without simultaneous engagement in open competitive examinations.
“Viewed thus, the 2023 Amendment operates on the probationary conditions as they exist during training and does not, in law, amount to a retrospective deprivation of any accrued or vested right.This conclusion follows not merely from the historical existence of such a prohibition, but from the settled principle that conditions governing probation and training are liable to change during service, subject to statutory authority,” the Court said.
It added that no vested or accrued right of the Petitioners stood crystallised to appear in the Civil Services Examination during probation, and no element of hostile discrimination or arbitrariness was made out.
The Bench ruled that the IFS probationers cannot claim a right to be governed, for all purposes, by the Rules prevailing on the date of their appointment, irrespective of subsequent amendments validly made during the period of probation.
“The Indian Forest Service (Probation) Amendment Rules, 2023 are applicable to the Petitioners notwithstanding the fact that they joined training prior to 23.11.2023, since the Amendment governs the period of training thereafter,” the Court said.
It added: “The denial of permission to appear in the Civil Services Examination during probationary training does not suffer from arbitrariness or illegality so as to warrant interference under Article 226 of the Constitution of India.”
Title: ABHIMANYU SINGH AND ANR v. UNION OF INDIA AND ORS & other connected matters