CAT - ['Lucknow']
Administrative and Public LawEmployment and Labour Law

An unambiguous Delhi-only jurisdiction clause excludes other CAT benches in centralized recruitment disputes.

Utkarsh Agarwal vs Union Of India

CAT - ['Lucknow']JUDGMENT: September 29, 20262 MIN READSOURCE JUDGMENT
An unambiguous Delhi-only jurisdiction clause excludes other CAT benches in centralized recruitment disputes.. Utkarsh Agarwal vs Union Of India. CAT - ['Lucknow']. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant challenged the rejection of his candidature for appointment as Administrative Officer in Kendriya Vidyalaya Sangathan and sought consideration for appointment with consequential benefits

Source reference: p.1

The respondents objected that the Lucknow Bench lacked territorial jurisdiction because clause 29 of the recruitment advertisement provided that disputes concerning the recruitment would be subject to courts having jurisdiction in Delhi only

Source reference: pp.2, 4

The applicant relied on Rule 6 of the Central Administrative Tribunal (Procedure) Rules, 1987, and argued that the objection had been raised after pleadings were exchanged

Source reference: p.2
02

Issues

Whether clause 29 of the recruitment advertisement excluded the territorial jurisdiction of the CAT Lucknow Bench, notwithstanding Rule 6 of the CAT (Procedure) Rules, 1987.

Source reference: pp.2, 4

Whether the Lucknow Bench could adjudicate the applicant’s challenge to the rejection of his candidature.

Source reference: pp.4–5
03

Law Applied

Rule 6 of the CAT (Procedure) Rules, 1987 provides for filing before the relevant Tribunal Bench, including where the applicant is posted or where the cause of action, wholly or in part, arose.

Source reference: p.2

The Tribunal relied on Yuvraj Singh Dilip Singh Zala v. Union of India & Ors., Special Civil Application No. 4528/2016 (Gujarat High Court, 14 June 2016), which held that an applicant who applies under an employment notice containing a clear jurisdiction clause is bound by that clause, and that such a clause may confer exclusive jurisdiction on one otherwise competent forum.

Source reference: pp.2–4

The Tribunal also referred to ABC Laminart Pvt. Ltd. v. A.P. Agencies, Salem, (1989) 2 SCC 163, on the validity and construction of agreements selecting one among otherwise competent forums, and to Rajasthan State Electricity Board v. Universal Petro Chemicals Ltd., (2009) 3 SCC 107.

Source reference: p.3
04

Reasoning

The Tribunal found clause 29—providing that disputes concerning the recruitment would be subject to courts having jurisdiction in Delhi only—to be unambiguous.

Source reference: p.4

It treated the recruitment as a centralized, all-India process and considered the reasoning in Yuvraj Singh Dilip Singh Zala applicable to the dispute.

Source reference: pp.3–4

On that basis, it held that the jurisdiction clause displaced reliance on Rule 6 as a basis for adjudication by the Lucknow Bench.

Source reference: pp.2, 4

The applicant’s point that the objection was raised after pleadings had been exchanged was recorded, but the Tribunal did not treat it as altering its jurisdictional conclusion.

Source reference: p.2
05

Holding

The CAT Lucknow Bench held that it lacked territorial jurisdiction to adjudicate the original application.

Rather than deciding the merits of the recruitment challenge, it directed the Registry to write to the Principal Bench at New Delhi to place the matter before the Chairman, CAT, with a proposal to transfer the OA to the appropriate forum.

Source reference: p.5
CAT - ['Lucknow']

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Utkarsh AgarwalvsUnion Of India

CAT - ['Lucknow'] · September 29, 2026

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