CALL FOR PAPERSVolume 2Issue 3Submit Research
Gender Justice/Labour LawResearch ArticleOPEN ACCESSPEER REVIEWED

CASE COMMENTARY ON A.K. KRAIPAK VS UNION OF INDIA, (1969) 2 SCC 262 (M. Hidayatullah, J.M. Shelat, K.S. Hegde, A.N. Grover, and Vashishtha Bhargava)

Volume
2
Issue
3
Pages
1–11
Published
Aug 2026
0
0
2
PDF Preview1–11
Loading preview…

Abstract

In 1966, the Government of India established a new All-India Service known as the Indian Forest Service (IFS) under the All-India Services Act, 1951 (All India Services Act, 1951). To staff this newly created service, the Central Government framed the Indian Forest Service (Initial Recruitment) Regulations, 1966 (Indian Forest Service Regulations, 1966). These regulations outlined that senior, qualified officers already serving within the provincial State Forest Services would be selected and integrated into the federal IFS cadre. It is worth noting that the IFS was the third All-India Service to be created, following the Indian Administrative Service and the Indian Police Service, and its formation reflected a broader post-Independence policy of bringing provincial cadres under a unified national framework to standardise administrative and technical governance. This centralising rationale explains why lateral entrants from the State Forest Services, such as the officers competing before the Special Selection Board in this case, had such a strong stake in how the initial recruitment exercise was conducted, since selection to the IFS carried significant career and status implications.[1] For State of J&K, a special selection board had been constituted to hold interview of the candidates, to evaluate their service record and prepare a merit list of the recommended officers for Central Civil Services Commission. This Selection Board consisted of many senior officers, one of whom was the Acting Chief Conservator of Forests for Jammu & Kashmir, Naqishbund. A serious conflict of interest situation arose because Naqishbund was not just a selector but an applicant too. He was one of the state cadre officers seeking a permanent, coveted slot in the initial recruitment selection list for the newly formed IFS. Despite this glaring overlap of roles, Naqishbund was appointed to and remained an active member of the Special Selection Board tasked with choosing the best officers from his own state.

Authors
SS
Shruti Santha Kumar
Keywords
Natural JusticeRule Against BiasReasonable Apprehension of BiasAdministrative LawA.K. Kraipak v. Union of India
References
No references listed.

Related Research