CAT cannot condone delay in filing review applications beyond Rule 17(1)’s thirty-day limitation.

The applicant sought review of the Tribunal’s order dated 20 June 2022 passed in O.A. No. 224 of 2016.

The Review Application was filed on 9 September 2025, more than three years after the impugned order, along with M.A. No. 1289 of 2025 seeking condonation of delay.

The applicant contended that the review could not be filed earlier because a contempt petition arising from the original order was pending, and that the review was filed after the contempt petition was closed on 5 September 2024.

The respondents opposed condonation, submitting that the original order had already been complied with, the contempt petition had consequently been closed, and the review was still filed more than one year thereafter.

Whether the delay in filing the Review Application, filed more than three years after the order sought to be reviewed, ought to be condoned on the ground that contempt proceedings were pending

Whether the Review Application was maintainable when it was filed beyond the thirty-day limitation period prescribed under Rule 17(1) of the CAT (Procedure) Rules, 1987

The Tribunal applied Rule 17(1) of the Central Administrative Tribunal (Procedure) Rules, 1987, which provides that no review application shall be entertained unless filed within thirty days from the date of receipt of the order sought to be reviewed.

Relying on K. Ajit Babu v. Union of India, 1997 (6) SCC 473, particularly paragraph 4, the Tribunal held that the power of review is a restricted remedy governed by the principles of Order XLVII Rule 1 of the Code of Civil Procedure and must be exercised within the prescribed limitation period.

It also relied on G. Narasimha Rao v. Regional Joint Director of School Education, Warangal, 2005 (4) SLR 720, for the principle that the Tribunal lacks jurisdiction to condone delay in review proceedings under the Limitation Act.

The impugned order was dated 20 June 2022, whereas the Review Application was filed only on 9 September 2025, substantially beyond the thirty-day period prescribed by Rule 17(1).

The Tribunal rejected the applicant’s explanation that the pendency of contempt proceedings prevented filing of the review, particularly because the original order had been complied with, the contempt petition had been closed on 5 September 2024, and the review was nevertheless filed more than a year later.

Applying K. Ajit Babu and G. Narasimha Rao, the Tribunal concluded that the delay could not be condoned and that the statutory limitation governing review could not be bypassed on the facts presented.

M.A. No. 1289 of 2025 seeking condonation of delay was rejected, and Review Application No. 54 of 2025 was consequently dismissed as time-barred.