Central guidelines adherence cannot confer Administrative Tribunal jurisdiction over non-notified autonomous state-level authorities.

The applicant, a retired Assistant Director of Agriculture, was appointed as a Facilitator by the State Agriculture Management Extension Training Institute (SAMETI – R3) and the Agriculture Technical Management Agency (ATMA – R4) for a specific term.

During his tenure, he was issued a show-cause notice alleging misconduct, subsequently resulting in the termination of his services via an order dated June 9, 2024 (Annexure A-3).

The applicant challenged this termination and the commencement of a new selection process before the Central Administrative Tribunal.

The respondents raised a preliminary objection regarding the maintainability of the Original Application (OA), arguing that R3 and R4 do not fall under the Tribunal's jurisdiction.

1. Whether the Central Administrative Tribunal (CAT) has jurisdiction over state-level agencies (R3 and R4) based on the "functional integrality" existing between them and a Central autonomous organization (R1 and R2).

2. Whether the mere adoption of recruitment and operational guidelines issued by a Central Government body (MANAGE) brings the implementing state-level authorities within the ambit of the Administrative Tribunals Act, 1985.

The Tribunal interpreted the jurisdictional scope of the Administrative Tribunals Act, 1985.

It examined the distinction between an "autonomous organisation of the Ministry of Agriculture & Farmers Organisation Welfare" (R1 and R2) and independent agencies (R3 and R4) that operate following central guidelines.

The court applied the principle that the source of the appointing and terminating authority determines the forum of jurisdiction, rather than the source of the operational guidelines followed by such authority.

The applicant argued that because R1 and R2 (MANAGE) issued the guidelines (Annexure A-6) governing the program, and retained the power to act on breaches of regulation, a "functional integrality" existed that placed R3 and R4 under CAT jurisdiction.

The Tribunal rejected this contention, noting that MANAGE is a distinct autonomous Central organization.

Upon perusing the termination order (Annexure A-3), the Tribunal found that the actual appointing and terminating authority resided exclusively with R3 and R4.

The Tribunal reasoned that an independent body does not fall within the "campus of authority" of the Administrative Tribunals Act simply because it follows guidelines issued by a Central body.

Consequently, since R3 and R4 are not notified entities under the Act, the Tribunal cannot exercise oversight over their employment decisions.

The application was rejected, though the Tribunal clarified that the applicant is not precluded from seeking relief before the appropriate legal forum.

No costs were ordered.