A belated representation cannot revive a time-barred challenge to a decades-old appointment.

The applicant challenged the Railway authority’s order dated 31 July 1998 appointing his brother, respondent No. 4, on compassionate grounds following the missing/death of their father, a Railway employee.

He alleged that the panchayatnama and resulting death certificate were false and sought cancellation of the appointment and an inquiry.

The applicant stated that he had made a representation in 2023; he filed the OA in 2026. The respondents objected that the challenge was time-barred.

1. Whether the OA, filed in 2026 to challenge a compassionate appointment made in 1998, was barred by limitation under Section 21 of the Administrative Tribunals Act, 1985.

2. Whether the applicant established a basis for the requested cancellation of the appointment or inquiry into the alleged false documents.

Section 21 of the Administrative Tribunals Act, 1985, generally requires an application challenging a final order to be filed within one year, subject to the statutory provisions concerning representations and sufficient cause for delay.

A belated representation does not, by itself, extend the limitation period; an application filed out of time may be admitted if the applicant satisfies the Tribunal that sufficient cause prevented timely filing.

The Tribunal cited no judicial precedents.

The appointment order was issued in 1998, but the applicant did not approach the Tribunal until 2026.

His representation was made only in 2023, long after the prescribed period, and the Tribunal found that no explanation for the substantial delay or separate application for condonation had been provided.

It therefore held that the OA could not be entertained because of delay and laches.

The Tribunal also noted the alleged personal enmity between the applicant and respondents Nos. 4 and 5; it did not, however, set out a separate substantive examination of the alleged falsity of the documents.

No separate merits analysis of the alleged forged documents appears in the order.

Pending miscellaneous applications, if any, were disposed of, and no order as to costs was made.