Union of India vs Rajeev Ranjan - 2026 Supreme(Online)(CAT) 4372

Headnote:(A) Administrative Tribunals Act, 1985 - Section 22(3)(f) - Central Administrative Tribunal (Procedure) Rules, 1987 - Rule 17 - Limitation Act, 1963 - Section 5 - Condonation of delay in filing review application - Whether the Tribunal is empowered to condone delay beyond the prescribed 30-day period under the Procedure Rules - Rule 17(1) specifies that no application for review shall be entertained unless filed within thirty days from the date of receipt of the order - There is a conflict of opinion among various High Courts regarding the applicability of Section 5 of the Limitation Act to the special procedure of the Tribunal - Some views suggest that the limitation period is not exclusionary of the Limitation Act, while other views maintain that since it is a special Act, no power to condone delay exists unless expressly conferred by the statute. (Paras 5, 8, 9, 10)

Facts of the case:
Review applicants filed a review application against an order dated 22.08.2024. The application was filed on 05.11.2024, resulting in a delay of 25 days beyond the 30-day limitation period prescribed under Rule 17 of the CAT (Procedure) Rules, 1987. The applicants filed a miscellaneous application seeking condonation of this delay.

Findings of Court:
The Tribunal observed that the Administrative Tribunals Act is a special Act and the Procedure Rules were framed under the powers conferred by the Act. Since Rule 17 expressly provides a timeline of 30 days and no provision within the Act or Rules expressly confers the power to condone such delay, the Tribunal cannot entertain an application for condonation of delay.

Issues: The main issue was whether the Central Administrative Tribunal has the authority to condone delay in filing a review application under Section 5 of the Limitation Act, 1963, in light of the restrictions imposed by Rule 17(1) of the CAT (Procedure) Rules, 1987.

Ratio Decidendi: The court followed the principle that in the case of a special Act, the Tribunal possesses no inherent power to condone delay unless such power is expressly granted by the creating statute. Therefore, the specific 30-day limit mentioned in Rule 17 of the CAT (Procedure) Rules is mandatory and cannot be extended via the general provisions of the Limitation Act.

Result: MA No. 2839/2024 and Review Application dismissed.

Legal Category Hierarchy

1. Review application under Section 22(3)(f) of Administrative Tribunals Act, 1985 — Delay of 25 days — Condonation sought. (Para 1 , 3 )

2. Review applicant argued for condonation relying on Allahabad High Court; respondent absent. (Para 4 , 8 )

3. Tribunal analyzed Rule 17 and conflicting high court decisions; concluded it lacks power to condone delay. (Para 5 , 6 , 7 , 9 , 10 , 11 , 12 , 13 )

4. Central Administrative Tribunal has no power to condone delay in filing review application under Rule 17 of CAT (Procedure) Rules, 1987. (Para 5 , 11 , 12 , 13 )

5. Miscellaneous Application for condonation of delay dismissed; Review Application dismissed accordingly. (Para 13 )

6. Can the Central Administrative Tribunal condone delay in filing a review application under Rule 17 of the CAT (Procedure) Rules, 1987?

No, the Tribunal has no power to condone delay because Rule 17 prescribes a 30-day limitation and the statute does not expressly confer such power. (Para 5 , 11 , 12 , 13 )

7. Does the Limitation Act apply to review proceedings before the Central Administrative Tribunal?

No, the Administrative Tribunals Act is a special Act; Rule 17 provides the limitation period and the Tribunal cannot invoke Section 5 of the Limitation Act to condone delay. (Para 11 , 12 )

O R D E R

This Review Application has been filed by the review applicant/respondents (in OA) under Section 22(3)(f) of the Administrative Tribunals Act, 1985 seeking review of the order dated 22.08.2024 passed in Original Application No. 060/1316/2022, along with, a Misc. Application No. 2839/2024 seeking condonation of delay of 25 days in filing the Review Application.

2. Despite sufficient opportunities granted by this Tribunal, none appeared on behalf of the respondents (original applicant in OA). Service report of review respondent on behalf of review applicant has also been filed on 19.12.2025.

3. On perusal of record, I find that the Order was passed by this Tribunal on 22.08.2024. It has been submitted by the review petitioner that a copy of the Order was received by him on 10.09.2024. 30 days’ time period expired on 10.10.2024. The RA has been filed on 05.11.2024, after expiry of 30 days from the date of receipt of the Order.

4. Heard learned counsel for the review applicant on M.A.

2839/2024.

5. The present Review Application has been filed after a delay of 25 days and, therefore, it is time barred as per Rule 17 of the C.A.T. (Procedure) Rules, which prescribed limitation for filing the review. The question which arises for consideration is whether the Tribunal is empowered to condone the delay in filing the Review Application. The Rule 17(1) of the Central Administrative Tribunal (Procedure) Rules, 1987 prescribes the procedure for filing the Review Application, which reads as under:-

“No application for review shall be entertained unless it is filed within thirty days from the date of receipt of copy of the order sought to be reviewed.”

6. The Rule 22 of the Administrative Tribunals Act, 1985 reads as under:-

“22. Procedure and powers of Tribunals – (1) A Tribunal shall not be bound by the procedure laid down in the Code of Civil Procedure, 1908 (5 of 1908) but shall be guided by the principles of natural justice and subject to the other provisions of this Act and of any rules made by the Central Government, the Tribunal shall have power to regulate its own procedure including the fixing of places and times of its inquiry and deciding whether to sit in public or in private.

(2) A Tribunal shall decide every application made to it as expeditiously as possible and ordinarily every application shall be decided on a perusal of documents and written representations and [after hearing such oral arguments as may be advanced].

(3) A Tribunal shall have, for the purposes of [discharging its functions under this Act], the same powers as are vested in a civil court under the Code of Civil Procedure, 1908 (5 of 1908) while trying a suit, in respect of the following matters, namely :-

(a) summoning and enforcing the attendance of any person and examining him on oath;

(b) requiring the discovery and production of documents;

(d) subject to the provisions of sections 123 and 124 of the Indian Evidence Act, 1872 (1 of 1872) requisitioning any public record or document or copy of such record or document from any office;

(e) issuing commissions for the examination of witnesses or documents;

(f) reviewing its decisions;

(g) dismissing a representation for default or deciding it ex- parte;

(h) setting aside any order of dismissal of any representation for default or any order passed by it ex-parte ; and (i) any other matter which may be prescribed by the Central Government.”

7. The Rule 17 of Central Administrative Tribunal (Procedure)

Rules, 1987 reads as under:-

“17. Application for review. - (1) No application for review shall be entertained unless it is filed within thirty days from the date of receipt of copy of the order sought to be reviewed.

(2) A review application shall ordinarily be heard by the same Bench which has passed the order, unless the Chairman may, for reasons to be recorded in writing, direct it to be heard by any other Bench.

(3) Unless otherwise ordered by the Bench concerned, a review application

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2026 Supreme(Online)(CAT) 4372

CENTRAL ADMINISTRATIVE TRIBUNAL
Ramesh Singh Thakur, J
Union of India – Appellant
Versus
Rajeev Ranjan – Respondent
RA No. 41/2024|OA No. 1316/2022|MA No. 2840/2024|MA No. 2839/2024

The Central Administrative Tribunal lacks the power to condone delay in filing review applications beyond the 30-day limit prescribed by Rule 17 of the CAT (Procedure) Rules, 1987, as such power must be expressly conferred by the statutory framework of the Administrative Tribunals Act, 1985.

Legal Category Hierarchy

Table of Contents

6. Can the Central Administrative Tribunal condone delay in filing a review application under Rule 17 of the CAT (Procedure) Rules, 1987?

7. Does the Limitation Act apply to review proceedings before the Central Administrative Tribunal?

2026 Supreme(Online)(CAT) 4372

CENTRAL ADMINISTRATIVE TRIBUNALRamesh Singh Thakur, JUnion of India – AppellantVersusRajeev Ranjan – RespondentRA No. 41/2024|OA No. 1316/2022|MA No. 2840/2024|MA No. 2839/2024

The Central Administrative Tribunal lacks the power to condone delay in filing review applications beyond the 30-day limit prescribed by Rule 17 of the CAT (Procedure) Rules, 1987, as such power must be expressly conferred by the statutory framework of the Administrative Tribunals Act, 1985.

Legal Category Hierarchy

Table of Contents

6. Can the Central Administrative Tribunal condone delay in filing a review application under Rule 17 of the CAT (Procedure) Rules, 1987?

7. Does the Limitation Act apply to review proceedings before the Central Administrative Tribunal?

CENTRAL ADMINISTRATIVE TRIBUNAL
Ramesh Singh Thakur, J
Union of India – Appellant
Versus
Rajeev Ranjan – Respondent
RA No. 41/2024|OA No. 1316/2022|MA No. 2840/2024|MA No. 2839/2024