The Central Administrative Tribunal (CAT) Allahabad has held that a superior officer's response on WhatsApp as "OK" to a leave request by a junior officer cannot by itself, be treated as conclusive proof of leave approval by the competent authority.

This when the administrative work of the department was under the charge another officer who was the competent authority for considering the applicant's plea for leave.

The CAT was hearing a Railway employee's plea challenging his transfer from Prayagraj to Fatehpur. The applicant, who was working as Chief Commercial Supervisor / Commercial Management Inspector, North Central Railway, said that he had gone to his native place after availing three days' leave from 14.07.2025 to 16.07.2025.

On 16.07.2025 he had requested for two additional days' leave–for 17.07.2025 and 18.07.2025, through WhatsApp which was approved by the Senior Divisional Commercial Manager/Coaching, Prayagraj by replying “OK”. The applicant further said that he had informed the Senior Divisional Commercial Manager/Freight, Prayagraj, about the matter telephonically on 17.07.2025. Thereafter when he joined duty he was transferred.

Judicial Member Rajnish Kumar Rai in his order observed that the applicant had relied upon the WhatsApp response “OK” allegedly given by the Senior Divisional Commercial Manager/Coaching, to contend that his request for additional leave for 17.07.2025 and 18.07.2025 had been approved.

However, the respondents, claimed that the concerned Senior Divisional Commercial Manager/Coaching was on training between 14.07.2025 to 25.07.2025 and during the this period the administrative work of the Commercial Department was under the charge of another officer–Senior Divisional Commercial Manager/Freight, Prayagraj.

The respondents said that the Senior Divisional Commercial Manager/Freight was the competent authority for sanction of the applicant's leave and that, in terms of the Railway Board and North Central Railway instructions, leave was required to be sanctioned through the HRMS portal. Further mere submission of a leave request did not amount to sanction of leave, the Railways said. The Railways claimed that the applicant had not received sanction from competent authority.

"From the aforesaid facts, it is apparent that the alleged WhatsApp response “OK” relied upon by the applicant cannot, by itself, be treated as conclusive proof of sanction of leave by the competent authority, particularly when the respondents have specifically stated that, during the relevant period, the administrative work of the Commercial Department was under the charge of Shri Atul Yadav, Senior Divisional Commercial Manager/Freight, who was the competent authority in respect of the applicant's leave.

The applicant's allegation of bias against the said officer, therefore, cannot be accepted merely on the ground that he was involved in the matter relating to the applicant's absence or subsequent disciplinary action. The applicant was transferred pursuant to the administrative process and after approval of the competent authority," the CAT held.

It said that the in view of the administrative exigency and the requirement of ensuring proper functioning of work, the action of the respondents cannot, in the absence of specific and cogent material, can be held as actuated by mala fide or something that would constitute a punishment in disguise.

The CAT said that Railways had disclosed an identifiable and independent administrative basis for the transfer– the development of the new entry and booking office at Fatehpur Railway Station, requirement of staff, availability of a vacant post and the applicant's continued posting in the Divisional Railway Manager's office since 2019.

It noted that the matter was placed before the Placement Committee and the transfer was thereafter approved by the competent authority.

"I am of the considered view that the impugned transfer cannot be held to be punitive in disguise merely on account of the subsequent initiation of disciplinary proceedings or the applicant's allegations concerning his leave. The respondents have demonstrated a separate and bona fide administrative exigency for transferring the applicant to Fatehpur against a vacant post, and the transfer was processed through the Placement Committee and approved by the competent authority. The applicant has failed to establish any cogent material showing that the impugned transfer was actuated by mala fides, was passed as a substitute for disciplinary punishment, or was otherwise vitiated by arbitrariness, violation of statutory rules or incompetence of the authority," it said.

The plea was dismissed.