Administrative delay cannot prejudice promotion; eligible service awards must be considered through a Review DPC.

The applicant, an employee of Northern Railway, applied for selection to three posts of Staff & Welfare Inspector under the 35% Limited Departmental Competitive Examination quota pursuant to notification dated 25 August 2023.

He qualified the written examination held on 16 March 2024, securing 86.67/100 marks and ranking third among the candidates who appeared.

He had received Certificates of Outstanding Service and a Group Cash Award issued under the authority of the Chief Rolling Stock Engineer (“CRSE”) for commendable work in the C&W Control Cell.

On 19 March 2024, before the DPC completed its assessment, he requested that these awards be entered in his e-Service Register.

The entry was, however, made only on 23 August 2024, after the panel had been published on 14 June 2024.

The applicant was awarded 24/30 marks for Record of Service, resulting in an aggregate score of 67.34/80.

The last selected candidate under the unreserved category secured 67.50/80.

The respondents maintained that the award was a collective Group Cash Award and not an individual Railway Week Award qualifying for additional marks under the applicable criteria.

The applicant’s subsequent representations were rejected by order dated 14 August 2025, leading to the present proceedings.

1. Whether the respondents unlawfully failed to place and consider the applicant’s CRSE Certificates of Outstanding Service and Group Award while assessing his Record of Service for selection to the post of Staff & Welfare Inspector?

2. Whether the administrative delay in updating the applicant’s e-Service Register, despite his request being made before completion of the DPC assessment, could prejudice his selection prospects?

3. Whether the applicant was entitled to reconsideration through a Review DPC/Selection Board and consequential empanelment if the reassessment placed him above the cut-off of 67.50 marks?

The Tribunal applied Section 19 of the Administrative Tribunals Act, 1985, under which an aggrieved employee may challenge an administrative action relating to service matters.

It relied on Master Circular No. 31, Railway Board letter dated 19 December 2019, and Northern Railway Personnel Serial No. 11862 dated 21 October 1999, which governed the assessment of Record of Service and recognition of commendable service in departmental selections.

The Tribunal applied the principle that an employee should not suffer adverse consequences in career progression because of administrative delay or default attributable to the employer.

It also relied upon the corrective mechanism of a Review DPC/Selection Board where an error or omission in placing relevant service material before the original DPC has affected the selection outcome, referring to the Tribunal’s decision in Praveen Kumar v. Union of India & Ors., O.A. No. 4349/2024, decided on 7 November 2025.

The Tribunal found that the applicant had acted diligently by seeking incorporation of his awards in the e-Service Register on 19 March 2024, before the selection process was completed, whereas the respondents updated the record only on 23 August 2024, after publication of the panel.

It held that the respondents’ restrictive approach of treating only individual Railway Week Awards as eligible for Record of Service weightage lacked sufficient support in the governing rules.

The CRSE, being a senior PHOD/HOD-level authority, had issued the Certificates of Outstanding Service, and those documents were relevant to the applicant’s service assessment.

Since the applicant’s aggregate score of 67.34 was only 0.16 marks below the cut-off of 67.50, even a fraction of additional credit could materially alter the result.

The non-placement of the certificates before the DPC therefore constituted an administrative omission capable of affecting the selection outcome.

The Tribunal consequently considered a Review DPC necessary rather than directly ordering appointment or promotion.

The respondents were directed to convene a Review DPC/Selection Board within eight weeks, reassess the applicant’s Record of Service after considering his updated e-Service Register and CRSE Certificates of Outstanding Service, and place him on the selection panel if his revised score equalled or exceeded 67.50/80.

In that event, he would receive notional promotion and seniority from the date on which his counterparts were empanelled.

No back wages were directed, applying the principle of “no work, no pay”; there was no order as to costs.