CAT - ['Jabalpur']

Compassionate Appointment is not a Vested Right and depends on Vacancy Availability and Relative Penury

Ravi Phalke vs Comptroller And Auditor General Of India

CAT - ['Jabalpur']JUDGMENT: May 12, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant’s father, a Senior Accountant in the respondent department, died in harness on 04.01.2010

Source reference: p. 2

The applicant applied for compassionate appointment on 25.02.2010. His initial application was rejected in 2011 due to a lack of vacancies and a policy change regarding married sons

Source reference: p. 2-3

The applicant previously filed OA No. 202/330/2015, where the Tribunal directed the respondents to consider his case two more times

Source reference: p. 3

Consequently, the Departmental Screening Committee (DSC) reconsidered his application in meetings held on 09.11.2017 and 29.10.2018

Source reference: p. 3, 7

On both occasions, the applicant was not selected as other candidates secured higher merit marks based on the revised evaluation parameters

Source reference: p. 7-8

The applicant challenged the order dated 09.11.2018, alleging arbitrariness and seeking consideration for vacancies from 2016–2019

Source reference: p. 3-4
02

Issues

1. Whether the respondents acted arbitrarily or in violation of the Tribunal’s earlier directions in rejecting the applicant's claim for compassionate appointment

Source reference: p. 7-8

2. Whether an applicant has a vested right to be appointed on compassionate grounds irrespective of merit and vacancy limitations

Source reference: p. 4, 9
03

Law Applied

Department of Personnel and Training (DoP&T) OM No. 14014/2/2012-Estd. (D), which limits compassionate appointments to 5% of direct recruitment vacancies in Group ‘C’

Source reference: p. 4

Himachal Road Transport Corporation v. Dinesh Kumar and Hindustan Aeronautics Ltd. v. Smt. Radhika Thirumalai, which establish that such appointments are contingent upon vacancy availability

Source reference: p. 4

Umesh Kumar Nagpal v. State of Haryana, affirming that compassionate appointment is not a vested right but an ameliorating relief to tide over immediate financial crises, and cannot be granted after a lapse of reasonable time

Source reference: p. 9-10

LIC v. Mrs. Asha Ramchandra Ambedkar, stating that Tribunals can only direct the "consideration" of a claim, not the appointment itself

Source reference: p. 4
04

Reasoning

The Tribunal found that the respondents had complied with the previous judicial direction to consider the applicant’s case two additional times

Source reference: p. 7

Upon review of the comparative merit charts provided by the respondents (Annexure R-5), the Tribunal noted that the applicant scored significantly lower (75 and 90 marks) than the selected candidates (who scored between 120 and 140 marks) in the 2017 and 2018 DSC meetings

Source reference: p. 7-8

The court observed that the respondents utilized an objective, revised evaluation system based on specific parameters to ensure fairness

Source reference: p. 8

Since the applicant failed to secure the required merit position and the selection process was conducted in an objective manner, there was no evidence of arbitrariness or "pick and choose" tactics

Source reference: p. 8-9

The court further emphasized that the objective of the scheme is to relieve immediate penury, and the applicant's family had managed to subsist for several years since the death in 2010

Source reference: p. 5, 9
05

Holding

The Tribunal held that the applicant had no vested right to appointment and that the respondents had fulfilled their legal obligation by considering his case three times in total

Directing a fourth or subsequent consideration was deemed unnecessary as the family had survived the immediate crisis. The Tribunal found no reason to interfere with the impugned order dated 09.11.2018 and dismissed the Original Application

Source reference: p. 10
CAT - ['Jabalpur']

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Ravi PhalkevsComptroller And Auditor General Of India

CAT - ['Jabalpur'] · May 12, 2026

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