Facts
The applicant applied for the post of TGT (Sanskrit) under the OBC (NCL) category in a centralized recruitment conducted under Employment Notice No. 01/2025. After qualifying the written examination and being called for interview/document verification, her candidature was rejected on 28 September 2026 on an issue concerning her OBC (NCL) certificate.
Source reference: para. 3She filed an Original Application before the Allahabad Bench, arguing that part of the cause of action arose in Uttar Pradesh because she resided in Prayagraj and her certificate was issued there.
Source reference: para. 4The respondents objected to territorial jurisdiction, relying on paragraph 24(q) of the Employment Notice, which provided that recruitment disputes would be subject to the jurisdiction of courts in Delhi only.
Source reference: paras. 2, 5Issues
Whether the Allahabad Bench had territorial jurisdiction to hear a challenge arising from the centralized recruitment, despite the Delhi-only jurisdiction clause in the Employment Notice
Source reference: paras. 2, 7–8Whether the applicant’s residence in Prayagraj or the issuance of her OBC (NCL) certificate in Uttar Pradesh was sufficient to confer territorial jurisdiction on the Allahabad Bench
Source reference: paras. 4, 8Law Applied
Rule 6 of the Central Administrative Tribunal (Procedure) Rules, 1987 concerns the place where an Original Application may be filed; the Full Bench in Shri Alok Kumar Singh v. Union of India, OA No. 458/1990 and connected matter, held that an application may be filed where an adverse order or communication gives rise to part of the cause of action.
Source reference: paras. 10–11In A.B.C. Laminart Pvt. Ltd. v. A.P. Agencies, Salem, (1989) 2 SCC 163, the Supreme Court held that parties may select one among otherwise competent forums, and a clear, unambiguous ouster clause—particularly one using terms such as “only”—may exclude other forums.
Source reference: para. 14The Tribunal also cited Rajasthan State Electricity Board v. Universal Petro Chemicals Ltd., (2009) 3 SCC 107, as reiterating that principle.
Source reference: para. 14Article 323-A of the Constitution enables Parliament to provide for administrative tribunals but does not, by itself, determine the territorial jurisdiction of a particular CAT Bench.
Source reference: para. 9Reasoning
The Tribunal found that the applicant’s grievance arose directly from the centralized recruitment governed by Employment Notice No. 01/2025.
Source reference: para. 7It held that her residence in Prayagraj and the Uttar Pradesh issuance of her certificate did not, by themselves, override the Notice’s express stipulation that recruitment disputes would be subject to the jurisdiction of courts in Delhi only.
Source reference: paras. 8, 15The Tribunal distinguished Alok Kumar Singh because that decision addressed the ordinary application of Rule 6 and did not concern a recruitment notice containing an express jurisdiction clause.
Source reference: para. 11It also distinguished Preeti Suman, which arose in a different service and procedural context.
Source reference: para. 12As the applicant had participated in the selection process under the notified terms, the Tribunal held that the Delhi-only clause applied to her dispute.
Source reference: paras. 13–15Holding
The Tribunal held that the Allahabad Bench lacked territorial jurisdiction and dismissed the Original Application as not maintainable, without examining the merits of the OBC (NCL) certificate dispute.
There was no order as to costs, and any pending miscellaneous applications were disposed of.
Source reference: para. 18Original Court PDF
Arti VishwakarmavsEDUCATION
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