Administrative Tribunal lacks jurisdiction over service claims concerning organizations not notified under the Administrative Tribunals Act.

The applicant was a Junior Accounts Officer (JAO) at the Prime Minister Memorial Museum Library (PMML), an autonomous body under the Ministry of Culture

In April 2023, he joined the Union Public Service Commission (UPSC) on a deputation basis

On 05.11.2024, UPSC issued an order for his permanent absorption, leading the applicant to tender a technical resignation from PMML and terminate his lien there

However, on 25.04.2025, UPSC withdrew the absorption order, claiming the applicant was ineligible because PMML is an autonomous body

During the proceedings, the UPSC produced a proposal based on DoPT advice allowing the applicant to continue on deputation for the maximum permissible period (up to seven years or superannuation) subject to an undertaking that his lien and pensionary benefits would remain with PMML

1. Whether the Central Administrative Tribunal has the jurisdiction to adjudicate service matters involving the Prime Minister Memorial Museum Library (PMML)

2. Whether the proposed arrangement to allow the applicant to continue on deputation in lieu of absorption is legally valid

The Tribunal primarily applied Section 19 and Section 14 of the Administrative Tribunals Act, 1985, which defines the jurisdiction of the Tribunal over notified organizations

It also considered the Department of Personnel and Training (DoPT) guidelines (OM dated 08.12.2025) governing deputation limits and service conditions for employees transitioning between autonomous bodies and the Central Government

The Tribunal found that PMML is not an organization notified under the Administrative Tribunals Act, 1985. Therefore, the Tribunal lacks the statutory jurisdiction to determine rights, such as lien or absorption claims, that emanate from PMML

Regarding the merits of the transition, the court noted that the Respondents (UPSC and PMML), following DoPT advice, had reached a consensus to allow the applicant to remain at UPSC on deputation until one month prior to his superannuation

The Tribunal reasoned that this arrangement was a "workable and lawful mechanism" that satisfied the applicant’s service requirements while adhering to the applicable rules

It concluded that since a reasonable course of action was offered and the primary employer (PMML) fell outside its jurisdiction, the application could not be entertained

The OA was dismissed; however, the Tribunal left it open for the applicant to accept the terms of the deputation and submit the required undertaking to UPSC to continue his services there in accordance with the law

No costs were awarded