The One Cadre Conundrum: Why Women Police Officers Need a Separate Cadre

The question of whether women police officers should be placed in a unified promotion cadre alongside male officers has emerged as a critical legal and institutional issue within Sindh’s police service framework. What appears at first glance to be an administratively neutral policy—the so-called “one cadre” system—has, in practice, produced structural disadvantages for women in the police service.

The issue therefore demands careful legal reconsideration in light of the governing statutory framework, judicial pronouncements, and the constitutional commitment to gender equality. This article traces the legal history, examines the constitutional questions, and explains how the one cadre system can create and widen a gender gap in the Sindh Police.

Historical Framework of Women in Policing

The roots of the issue lie in the early administrative structure of the police force, where male and female officers were historically treated as part of a single unified service. Prior to the promulgation of the Sindh Women Police Rules, 1998, there was no independent administrative or promotional structure specifically designed for women police officers.

Promotions and seniority were therefore determined collectively, without acknowledging the vastly different recruitment patterns and numerical representation of women within the force.

The Sindh Women Police Rules, 1998

Recognizing the structural barriers faced by women in policing, the Government of Sindh introduced the Sindh Women Police Rules, 1998. These rules were not merely procedural regulations; they represented a deliberate policy decision aimed at institutionalizing women’s participation in law enforcement. The objective was to ensure that female police personnel would have a viable career progression within the department.

Crucially, Rule 18 of the Sindh Women Police Rules, 1998 expressly provided for the maintenance of a separate seniority list and cadre for women police officers. This framework acknowledged the reality that women were recruited in far smaller numbers and therefore required a promotion structure that would allow meaningful representation in higher ranks.

The 2008 Administrative Attempt to Abolish the Separate Cadre

Despite the clear statutory framework, the issue resurfaced in 2008 when the Inspector General of Police, Sindh issued a notification purporting to abolish the separate seniority cadre for women police officers. The notification attempted to merge male and female personnel into a unified cadre system. However, this administrative directive did not produce significant immediate consequences because it remained largely unimplemented within the department.

The Sindh Service Tribunal’s Decision

The legal status of the notification eventually came under scrutiny during litigation before the Sindh Service Tribunal. In Mst. Zulekha and others v. Government of Sindh, the Tribunal examined the legality of reversion orders issued against several police officers following directions from the Supreme Court regarding officers promoted on ad-hoc or acting basis. While implementing those directions, the police department had reverted numerous officers who had been serving in promoted positions for extended periods.

The Tribunal held that the department had exceeded the scope of the Supreme Court’s directives and set aside the reversion orders. More importantly, the Tribunal reaffirmed that the service structure of women police officers remained governed by the Sindh Women Police Rules, 1998, thereby recognizing the continued existence of a separate women police cadre. In doing so, the Tribunal effectively nullified the 2008 notification of the IGP Sindh that had sought to abolish the separate cadre.

Misinterpretation of Judicial Precedent: Gul Hassan Jatoi

The controversy took a new turn following the judgment of the Supreme Court in Gul Hassan Jatoi v. Faqeer Muhammad Jatoi (2016 SCMR 1254). The case itself did not concern the status of women police officers. Rather, the dispute involved police personnel who had been transferred from one branch of the police department to another and subsequently promoted earlier than officers who were already serving in the receiving branch.

In resolving that dispute, the Supreme Court held that the existence of different branches within the police department does not necessarily mean that each branch constitutes a separate cadre. However, the judgment did not address the legal status of the women police cadre under the Sindh Women Police Rules, 1998, nor did it order the abolition of the separate cadre for female officers.

In fact, Paragraph 67 of the judgment indirectly supports the principle that separate cadres may legitimately exist where the entry point and recruitment mechanism differ. Women police officers are recruited under a distinct framework, often through quotas or specialized recruitment drives aimed at improving gender representation. Therefore, the factual basis of the Supreme Court’s reasoning in Gul Hassan Jatoi does not logically apply to the women police cadre.

Despite this, the police department interpreted the judgment broadly and proceeded to abolish the separate women police cadre, merging male and female officers into a single seniority pool.

We acknowledge that a Sindh High Court Division Bench (C.P. No. D-273 of 2023, order dated 6 February 2023) upheld the IGP’s notification of 15 December 2022 restoring the unified cadre, relying “more particularly” on para 56 of Gul Hassan Jatoi. The petition was decided on the day it was heard, without written comments from the Government. Respectfully, the decisive passage is paragraph 67: “the concept of ‘Cadre’ within the Police service could only be introduced if it is established that the recruitment process, the training and practical training of the members of Police Force is distinct.” The Women Police Rules, 1998, made by the Government of Sindh itself under the Police Act, 1861, provide a separate entry route: direct recruitment of lady constables and ASIs capped at five per cent of posts, a cadre strength fixed by Government and, under Rule 18, “a separate seniority list of Women Police Cadre”.

The High Court found that “the entry point of all the police personnel in executive police is common”, but under Rule 4 women are recruited through a Selection Board against their own requirements: Matric for lady constables, at least a second-class graduate degree for lady ASIs, an age of 18 to 28 and a minimum height of 5′2″. In our view, different entry requirements mean a different entry point, which goes to the heart of the paragraph 67 test. Equally, the Court’s concern that the cadre was created “without the concurrence of the competent authority i.e. Government of Sindh” sits uneasily with the Rules’ own preamble, which records that the Government of Sindh made them.

Paragraph 56 merely sets out the six promotion lists under the Police Rules, 1934; it does not mention women. The remark in paragraph 65 that “There is no concept of cadre within the Police, which is one indivisible force”, and the direction in paragraph 71 for “common seniority of Police Personnel serving in all the establishments”, were made in the context of the Rule 1.4 establishments, such as the Sindh Reserve Police, not separately framed rules for women police. Indeed, the Advocate General of Sindh told the Supreme Court (paragraph 27) that “it was only the Prosecution Branch, the Telecom Branch and the Female Police which could be categorized separately as cadres”. Read with Article 25(3), which permits special provision for women, the issue merits reconsideration by a larger bench or by the Supreme Court.

Structural Inequality in the One Cadre System

While the unified cadre may appear formally neutral, its practical consequences reveal a structural imbalance. Women constitute only a small fraction of the police force. When promotions are determined solely through a single seniority list that is overwhelmingly male, women officers inevitably find themselves at a systemic disadvantage.

Promotion in the police service is largely seniority-based. Because far fewer women are recruited at the entry level, the probability that women will reach higher ranks through a unified cadre becomes significantly diminished. Over time, this results in a near absence of women in senior leadership positions within the police hierarchy.

Thus, a policy that appears neutral in theory produces disproportionately unequal outcomes in practice. This phenomenon is well recognized in constitutional jurisprudence, where courts have repeatedly emphasized that equality must be assessed not only in terms of formal rules but also in terms of their real-world impact.

How the One Cadre System Can Widen the Gender Gap

The disadvantage is not limited to where women sit on a seniority list. A single cadre changes the conditions of service around promotion, and several of those conditions weigh more heavily on women in practice. None of these effects requires anyone to intend discrimination; they follow from applying one set of rules to two groups whose circumstances differ.

Seniority arithmetic and promotion bottlenecks

In a separate cadre, vacancies in higher ranks reserved for women are filled from among women. In a merged list, every vacancy is filled from one long queue. Because women enter in smaller batches, they are spread thinly through that queue, and a promotion round can pass with few or no women reaching the cut-off.

The merger itself can also cause disruption. Re-fixing seniority across two lists may push officers down, delay due promotions or reopen settled positions. Where court records or departmental orders show promotions being held back while lists are reconciled, the delay falls on officers who have already waited longest for advancement.

Transfers, postings and family relocation

A wider cadre usually carries wider transfer liability. Promotion in a unified structure may depend on accepting postings in distant districts or field units. Society still expects women in Pakistan to carry most caregiving duties, and many families are reluctant to relocate for a wife’s or daughter’s posting. As a result, the same transfer rule can be a routine inconvenience for one officer and a reason to decline promotion for another.

When an officer turns down a posting, or seeks to stay near home, her career may stall. Over time, this can be recorded as lack of willingness or experience, even though the cause is structural.

Training and eligibility requirements

Police promotions are tied to prescribed training courses and promotion lists under the Police Rules, 1934. Residential courses held away from home, without suitable accommodation or childcare arrangements, can be harder for women to attend. Missing or delaying a course delays eligibility, which compounds the seniority problem.

Attrition and the leadership pipeline

Slower promotion and heavier relocation burdens can push women to leave the service mid-career. Each departure shrinks the pool from which future senior officers are drawn. Fewer women in senior posts then means fewer role models, mentors and decision-makers attentive to these issues, and the cycle repeats.

Representation in senior posts

The cumulative effect is a narrowing pyramid: women may continue to be recruited at entry level while remaining rare in ranks such as Inspector, DSP and above. That gap matters not only for the officers concerned but for the public they serve, as explained below.

A balanced view

Supporters of a unified cadre argue that it treats all officers alike, opens the full range of operational postings to women, and avoids confining them to a limited set of roles. Some women officers have, in the past, voiced similar concerns about being sidelined within a separate cadre. Those concerns are legitimate. The answer, however, need not be a choice between a separate cadre and a single seniority list with no safeguards.

Measures such as protected seniority on merger, a minimum share of promotion slots for women, posting policies that take family circumstances into account, accessible training, and regular publication of data on women’s recruitment, promotion and attrition by rank could preserve the benefits of integration while preventing the gender gap from widening.

Constitutional Imperatives: Article 25

The Constitution of the Islamic Republic of Pakistan provides a clear normative framework for addressing such structural disparities. Article 25(1) guarantees equality before the law, while Article 25(2) prohibits discrimination on the basis of sex. At the same time, Article 25(3) explicitly permits the State to make special provisions for the protection of women and children.

The separate cadre established under the Sindh Women Police Rules, 1998 represents precisely the type of protective measure contemplated by Article 25(3). Its purpose was not to grant preferential treatment but to remove structural barriers that historically prevented women from advancing within the police service.

By abolishing the separate cadre and forcing women to compete within an overwhelmingly male seniority pool, the current policy risks undermining the constitutional objective of substantive equality, particularly when its effects on postings, training and attrition are taken into account.

The Institutional Importance of Women in Policing

The issue is not merely about promotions or internal administrative arrangements. Women police officers perform a vital institutional role within the justice system. Their presence is essential for addressing crimes involving women and children, conducting gender-sensitive investigations, and improving public confidence in law enforcement.

International policing standards increasingly recognize the importance of gender diversity within law enforcement agencies. Countries across the world have adopted targeted recruitment policies, specialized training programs, and promotion safeguards to ensure that women remain adequately represented within police leadership structures.

In Pakistan, where cultural and social barriers often discourage women from approaching male officers, the presence of women police personnel becomes even more critical.

The Need for Policy Reconsideration

The current “one cadre” policy therefore raises serious legal and policy concerns. The abolition of the separate cadre was not mandated by the Supreme Court, nor does it align with the original purpose of the Sindh Women Police Rules, 1998. More importantly, it fails to address the structural imbalance created by the numerical underrepresentation of women within the police force.

A more balanced and constitutionally sound approach would involve restoring the separate women police cadre or adopting alternative promotion mechanisms that ensure fair representation of women at higher ranks. Such reforms would not undermine merit; rather, they would ensure that institutional structures do not unintentionally exclude an entire segment of the workforce from meaningful career progression.

Officers affected by seniority fixation, reversion or denial of promotion have remedies before the Sindh Service Tribunal and, in appropriate cases, through constitutional petitions before the High Court. Our service and administrative law and constitutional law teams advise on such matters, and selected decisions are available on our Notable Judgments page.

Conclusion

The “one cadre” policy has transformed what should have been a straightforward administrative arrangement into a profound institutional dilemma. By merging male and female officers into a single promotion structure without addressing the underlying imbalance in recruitment numbers, and without accounting for the posting and relocation burdens that fall more heavily on women, the policy effectively limits the advancement prospects of women police officers.

In its present form, the system lacks a sound legal basis.

Restoring a separate promotional cadre for women, as originally envisioned under the Sindh Women Police Rules, 1998, would better reflect the constitutional commitment to gender equality under Article 25 of the Constitution and promote meaningful representation within the police hierarchy.

Until such reforms are undertaken, the “one cadre” system, which amounts to discrimination disguised as uniformity, will remain a persistent conundrum—one that raises fundamental questions about fairness, representation, and the future of women in Pakistan’s law enforcement institutions.

Frequently asked questions

What is the one cadre system in the Sindh Police?

It is the policy of placing male and female police officers in a single cadre with one combined seniority list for promotion, instead of the separate women police cadre and seniority list provided under the Sindh Women Police Rules, 1998.

Did the Supreme Court order the abolition of the women police cadre?

In our view, no. Gul Hassan Jatoi v. Faqeer Muhammad Jatoi (2016 SCMR 1254) concerned transfers between branches of the police and did not decide the status of the women police cadre under the 1998 Rules. The department’s reading of the judgment has, however, been relied upon to merge the lists, and the position should be checked against the latest court decisions in any individual case.

How can a single seniority list widen the gender gap?

Because women are recruited in smaller numbers, they are spread thinly across a combined list and fewer reach promotion cut-offs. Wider transfer liability, residential training requirements and family relocation pressures can add further delays, which over time can increase attrition and reduce the number of women in senior posts.

Does Article 25 of the Constitution allow special measures for women?

Yes. Article 25(3) of the Constitution of Pakistan states that nothing in Article 25 prevents the State from making any special provision for the protection of women and children. A separate cadre or protected promotion mechanism can be defended on that basis.

What can an affected police officer do?

An officer aggrieved by seniority fixation, reversion or denial of promotion can usually pursue a departmental remedy and then approach the Sindh Service Tribunal, or in suitable cases file a constitutional petition before the High Court. Time limits apply, so early legal advice is important.

Disclaimer: This article is general information about the law in Pakistan as at the date shown. It is not legal advice and does not create a lawyer-client relationship. Laws, fees and procedures change; please take advice on your own facts before acting.