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2025 Supreme(Online)(CAT) 13215

CENTRAL ADMINISTRATIVE TRIBUNAL
Mrs. Harvinder Kaur Oberoi, M (J), Dr. Sumeet Jerath, M (A)
Niranjan Kumar – Appellant
Versus
UNION OF INDIA Through Secretary Ministry of Railways – Respondent
O.A. No. 296/2025 | M.A No. 4724/2025 | M.A No. 296/2025 | M.A No. 297/2025 | M.A No. 3709/2025



Advocates:
For the Appellants/Petitioners: Mr. Shrikant Prasad, Mr. Aryan Kumar
For the Respondents: Mr. R. V. Sinha, Mr. A. S. Singh, Mr. Ashish Singh, Ms. Shriya Sharma, Ms. Jyoti Garg, Mr. Akshit Pradhan with Ms. Muskan Goyal and Mr. Vikash Chaurasia CLA, NRHQ

Public authorities have the discretion to revise recruitment criteria based on administrative needs, maintaining fair competition while legitimate expectations must align with publicly established practices.

Headnote:(A) Administrative Tribunals Act, 1985 - Section 19 - Recruitment criteria - Applicants sought to quash the revision in educational qualifications for Level-1 posts as unfair - Court examined the legitimacy of expectations of candidates based on previous eligibility criteria - Decision to change qualifications deemed justified by administrative needs - Applicants’ concerns on transparency noted but ruled insufficient to impede policy changes. (Paras 1-14)

(B) Principle of Legitimate Expectation - The doctrine emphasizes that public authorities should honor prior practices unless compelling reasons necessitate changes - New eligibility criteria were deemed valid and did not constitute an infringement of applicants' rights, as opportunities to participate remained unchanged. (Paras 5-16)

Facts of the case:
The applicants, aspiring for Level-1 posts in Railways, challenged the abrupt revision of minimum educational qualifications from 10th pass + ITI to 10th pass or ITI alone, affecting eligibility of approximately 39 lakh candidates and raising issues of transparency and fairness.

Findings of Court:
The court found no infringement of applicants’ rights or expectations; the revisions were valid based on administrative discretion, ensuring fair competition without unduly complicating the recruitment process.

Issues: The main issues included the legitimacy of applicants’ expectations regarding recruitment qualifications and the public authority’s right to change such criteria within its discretion.

Ratio Decidendi: The tribunal determined that procedural fairness did not preclude the authority's right to adjust recruitment standards, affirming that the applicants still retained access to the recruitment process.

Result: The application was dismissed, and there were no costs.

Table of Content
1. change in educational qualifications for recruitment. (Para 2 , 3)
2. arguments against changing eligibility criteria and impact on aspirants. (Para 4 , 5)
3. court's analysis of applicants' rights and administrative discretion. (Para 6 , 7 , 8)
4. affirmation of legitimate expectations and administrative rights to revise rules. (Para 12)
5. final judgement dismisses application based on merits. (Para 13)

ORDER

Hon'ble Dr. Sumeet Jerath, Member (A):

M.A No. 296/2025 :-

The instant M.A for joining together of parties in a single OA is allowed as all the applicants have a common cause of action and are seeking similar reliefs. O.A No. 296/2025 :-

The instant OA has been filed by Shri Niranjan Kumar and three other applicants – Babloo, Manish Kumar and Rajesh Kumar under section 19 of the Administrative Tribunals Act, 1985 seeking the following reliefs:-

"1. To quash Annexure A of CEN 08/2024 Dated 21.01.2025 Attached as Al. issued by the Railway Recruitment Board, which revised the minimum educational qualifications for Level-1 recruitment without adequate publicity, creating unfair competition.

2. Direct the Respondents to proceed with CEN 08/2024- recruitment using the earlier prescribed qualifications of 10th pass plus ITI or NAC, as consistently communicated since 2018 and justified in Letter No. E(NG)II/2018/RR-I/13 dated 25.09.2018, emphasizing the need for technical proficiency.

3. Grant any other relief deemed appropriate in the interests of justice.”

2. The factual matrix of the case as per the counsel of the applicants is that the applicants are aspirants for various posts in Level 1 of 7th CPC Pay Matrix in the Railways who are aggrieved by the sudden revision in the minimum qualification requirements for Level-1 posts in Railways vide Circular No. CEN 08/2024. They are challenging the same. According to the counsel of the applicants between the period from 2018 to 2024 various circulars had been issued by the Railways specifying the minimum educational qualifications as 10th pass + ITI. However, by way of Annexure A, the minimum educational qualification had been reduced to 10th Pass or ITI or equivalent or NAC which has significantly widened the eligibility criteria thereby affecting approximately 39,20,067 candidates who prepared themselves as per the earlier qualifications. The abrupt change also undermines the principles of transparency and the legitimate expectations of the aspirants. Moreover, it creates an environment of increased competition by allowing just 10th Pass candidates to participate in the examination. Aggrieved, they have chosen to file the present OA.

3. The counsel of the applicants argued vociferously using the following grounds :-

“1. Based on the repeated and consistent communications from the Railway Ministry over several years, including a clear and unambiguous direction to prepare for exams with qualifications of 10th pass ITI or NAC, thousands of aspirants, including the Petitioners, invested considerable time, effort, and financial resources to complete their ITI courses or obtain their NAC certificates.

2. That thousands of aspirants have invested considerable time, resources, and effort in pursuing ITI courses since 2019, based on the continuous conduct of railways and repeated intimation regarding the eligibility criteria.

3. Candidates were under the reasonable belief that the qualifications set by the Ministry for Level-1 recruitment would remain static, and they specifically tailored their educational and career plans accordingly.

4. This sudden deviation from the long-standing criteria lacks adequate publicity and goes against the legitimate expectations of Around 39 Lakhs 20 Thousands sixty seven (39,20,067) No of aspirants who prepared themselves as per the earlier qualifications.

5. During 2019 Onwards till date a RTI No DEGOT/R/E/24/00688 shows that around 39 lakhs students have undergone ITI Courses since 2019.”

4. During the course of hearing the counsel of the applicants h

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