CAT Lacks Power to Condon Delay Beyond 30-Day Limit for Review Applications.

The respondents filed a Review Application and a Misc. Application No. 364/2026 seeking condonation of a 77-day delay in filing the Review Application for an order dated October 14, 2025, passed in Original Application No. 060/00892/2018

1. Whether the Central Administrative Tribunal is empowered to condone a 77-day delay in filing a Review Application beyond the 30-day limitation period prescribed by Rule 17 of the C.A.T. (Procedure) Rules, 1987

The court primarily applied Rule 17(1) of the Central Administrative Tribunal (Procedure) Rules, 1987, which stipulates that "No application for review shall be entertained unless it is filed within thirty days from the date of receipt of copy of the order sought to be reviewed"

It further relied on the Supreme Court's pronouncement in K. Ajit Babu, which held that the right of review is available on limited grounds and within the period of limitation, asserting that the Tribunal's decision attains finality if not reviewed or appealed against within time

Additionally, the Gauhati High Court's ruling in Chanchal Nag was cited, which opined that a Tribunal has no power to condone delay unless expressly conferred by the statute creating it, and that the Limitation Act, being a general law, does not govern proceedings under the Administrative Tribunals Act

The court noted that the Review Application was filed after a delay of 77 days, thus being time-barred as per Rule 17 of the C.A.T. (Procedure) Rules, 1987, which mandates a 30-day limitation for filing such applications

Citing the Supreme Court's decision in K. Ajit Babu, the court reiterated that the right of review is limited to specific grounds and strictly subject to the period of limitation, emphasizing the public policy need for finality in legal decisions

Furthermore, by referencing the Gauhati High Court's judgment in Chanchal Nag, the court established that Tribunals lack inherent power to condone delays unless explicitly granted by the statute that created them, and that the general provisions of the Limitation Act do not apply to such specific statutory timelines

Given that Rule 17 explicitly provides a 30-day timeline without conferring discretion to condone delay, the Tribunal found itself without the authority to entertain the delayed application

Accordingly, Misc. Application No. 364/2026, seeking condonation of delay, was dismissed, and consequently, the Review Application was also dismissed