The Supreme Court of India has ruled that Forest Range Officers (FROs) in Andhra Pradesh are part of the State Forest Service (SFS) and can be considered for promotion to the Indian Forest Service (IFS), provided recruitment rules are followed. The judgment, delivered on 22 August 2025 by a Bench of Justice Dipankar Datta and Justice Augustine George Masih, overturned a previous decision of the Andhra Pradesh High Court.
Case Background
The case arose when P. Maruthi Prasada Rao, appointed as a Forest Range Officer in 2006 and later promoted as Assistant Conservator of Forests (ACF) in 2020, sought recognition of FROs as part of the State Forest Service. He argued that their exclusion from IFS promotion violated Articles 14 and 16 of the Constitution, which ensure equality and non-discrimination.
In 2022, the Central Administrative Tribunal (CAT), Hyderabad, had agreed with him and directed authorities to treat FROs as part of the State Forest Service for promotion to IFS. However, the Andhra Pradesh High Court reversed this in December 2023, holding that FROs were not included in the SFS as per the Recruitment Rules.
The apex court clarified that under Rule 2(g) of the Indian Forest Service (Recruitment) Rules, 1966, the definition of State Forest Service covers any service connected with forestry, with members holding gazetted status, subject to approval by the Central Government in consultation with the State Government.
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The Court noted that the Andhra Pradesh Forest Service Rules, 1997 include both Assistant Conservators of Forests and Forest Range Officers under Class A gazetted posts. Hence, FROs must be treated as part of the State Forest Service.
Justice Datta observed:
“Members of Class A of the Andhra Pradesh Forest Service, including Range Officers, are members of the State Forest Service if substantively appointed. As a sequitur, they are eligible for promotion to the Indian Forest Service.”
While the Court upheld the legal recognition of FROs as eligible, it denied retrospective relief to the appellant. The judges noted that Rao first raised his grievance only in January 2021, long after completing eight years of service in 2014.
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Quoting the earlier precedent of P.S. Sadasivaswamy v. State of Tamil Nadu (1975), the Bench stressed that delayed claims cannot unsettle settled matters. Thus, Rao could not claim consideration for past promotion exercises.
“The appellant succeeds insofar as the legal issue is concerned but without any real relief of promotion at least at this stage,” the Court remarked.
The Supreme Court set aside the Andhra Pradesh High Court’s order and directed that in future IFS promotion exercises, FROs must be considered eligible along with other State Forest Service officers.
The appeal was disposed of with no order on costs.
Case Name: P. Maruthi Prasada Rao vs. The State of Andhra Pradesh & Ors.
Case Type: Civil Appeal (Arising out of SLP (C) No. 1253 of 2024)
Date of Judgment: 22 August 2025
