CAT - Delhi

Administrative authorities must conduct Departmental Promotion Committees time-boundly to prevent indefinite stalling of promotional avenues.

Anjali Bhardwaj vs GNCTD

CAT - DelhiJUDGMENT: March 03, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The five applicants are Food Safety Officers (FSOs) under the Department of Food Safety, Government of NCT of Delhi.

Source reference: p. 4

Out of nine sanctioned posts for Designated Officers, seven remain vacant.

Source reference: p. 4

Although vigilance clearance reports for 14 eligible officers were requested on June 19, 2025, the respondents failed to convene a Departmental Promotion Committee (DPC).

Source reference: p. 4

The respondents contended that the DPC process was initiated prior to the filing of the OA but was delayed due to requests for additional information from the Competent Authority.

Source reference: p. 5

The Tribunal allowed the applicants to pursue the OA jointly (MA 3839/2025) and permitted the deletion of the Union of India (Respondent No. 5) from the proceedings as they were not a necessary party for the relief claimed.

Source reference: p. 3
02

Issues

1. Whether the delay in convening the Departmental Promotion Committee (DPC) for the post of Designated Officer by the respondents is legally sustainable.

Source reference: p. 5-6

2. Whether the Tribunal should intervene to mandate a time-bound conclusion of the promotional process.

Source reference: p. 6
03

Law Applied

The court primarily applied the administrative principles and mandates issued by the Department of Personnel and Training (DoPT), which require that DPCs be convened in a regular and time-bound manner.

Source reference: p. 6

The Tribunal emphasized the "bounden duty" of the administration to ensure promotional avenues are not indefinitely stalled to maintain the morale and motivation of eligible officers and ensure administrative efficiency.

Source reference: p. 6
04

Reasoning

The Tribunal observed that while the respondents had initiated preliminary steps toward conducting the DPC, the progress was "considerably delayed" and characterized by a "slow pace".

Source reference: p. 5

Despite seven out of nine posts being vacant for several years, the respondents failed to provide a concrete timeline for finalizing the DPC, citing vague "administrative reasons".

Source reference: p. 5

The Tribunal criticized the Department of Food Safety’s approach as "lackadaisical".

Source reference: p. 6

Applying the DoPT mandates, the court reasoned that the failure to conduct regular DPCs undermines administrative efficiency and unfairly stalls the career progression of eligible officers.

Source reference: p. 6

Consequently, judicial intervention was deemed necessary to prevent further indefinite delays.

Source reference: p. 6
05

Holding

The Tribunal disposed of the OA by directing Respondent No. 3 (Commissioner, Department of Food Safety) to ensure that the DPC for promotion to the post of Designated Officer is convened and concluded within three months from the date of receipt of the order.

The court held Respondent No. 3 personally liable for any further delays.

Source reference: p. 6

The Tribunal ordered that copies of the judgment be sent to the Chief Secretary of GNCTD to ensure compliance.

Source reference: p. 7

No orders were made as to costs.

Source reference: p. 6
CAT - Delhi

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Anjali BhardwajvsGNCTD

CAT - Delhi · March 03, 2026

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