Ambiguous wordings in the Kerala Administrative Service (KAS) rules, 2018, could deny the last remaining ‘direct recruit’ deputy collectors their right to be promoted to the Indian Administrative Service.
These deputy collectors are potential collateral damage after the KAS rules came into force on January 1, 2018. While the KAS was introduced to create a structured state civil service below the IAS, its transitional provisions seem to have disenfranchised a small group of deputy collectors recruited under the previous system.
Before the introduction of the KAS, officers promoted to the IAS from Kerala were drawn from the state civil service, which primarily comprised directly recruited deputy collectors under the Kerala Civil Service (Executive) Special Rules, 1963.
The shortage of direct-recruit deputy collectors was one of the factors that prompted the creation of the KAS; nearly 80 per cent of deputy collector posts were filled through promotion. Under Kerala Civil Service (Executive) Special Rules, 1963, one-fifth of deputy collector posts had to be filled by direct recruitment.
The KAS Rules, 2018, discontinued the direct recruitment of deputy collectors. In other words, the direct-recruit deputy collectors who could potentially be affected by the KAS rules were among those who had taken the last test for deputy collectors in Kerala.
Nonetheless, on the face of it, the KAS rules, 2019, is protective of the last of the deputy collectors. Section 19(a) of the KAS rules, 2018, says that officers appointed under the 1963 special rules and those who had joined before January 1, 2018 (the day KAS rules came into force) will have priority over KAS officers when it comes to promotion to the IAS.
The devil is in the phrase “who had joined before January 1, 2018”. The rule-affected deputy collectors, eligible to be promoted as IAS officers, were appointed after this date for no fault of theirs.
They had found a place in the last deputy collector rank list prepared under the Kerala Civil Service (Executive) Special Rules, 1963. The recruitment process had begun long before the KAS rules came into force, with vacancies already reported to the Public Service Commission. However, the process of advice and appointment was completed only after January 1, 2018.
These deputy collectors, though recruited through the same process, could be in danger of being deprived of substantial career advancement other officers from the same batch now enjoy. More than a year ago, in March 2025, five deputy collectors appointed from the same 2014 rank list were promoted as IAS officers.
The state administration, too, seems confused. Section 17(b) of KAS rules says that there will be “no appointments by direct appointment” under the 1963 special rules after January 1, 2028. Fact is, at least four deputy collectors have been appointed in the revenue department after the date.
But the government seems to have cleared all confusions in an order issued on January 27, 2025. It defined ‘state civil service’ in unambiguous terms. “Posts of deputy collectors appointed prior to January 1, 2018, until the completion of their tenure, along with the posts of Kerala Administrative Service Officer shall henceforth form the State Civil Service,” says the order.
Meaning, deputy collectors “appointed” after January 1, 2018, are not part of the State Civil Service on whose members alone IAS is conferred. They will be deprived of the IAS tag while colleagues who were part of the same rank list have attained IAS promotion. A clear case of differential treatment.
A General Administration Department official Onmanorama talked to said that some of the affected parties had approached the Kerala Administrative Tribunal and the KAT, in turn, has asked the Kerala government in May to submit its opinion on the issue within three months.
