CAT - ['Delhi']

Competent Authority Must Reasonably Exercise Statutory Discretion To Consider Relaxation of Qualifications for Promotion.

Dr Anil Baloni vs GNCTD

CAT - ['Delhi']JUDGMENT: April 27, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

Twelve applicants, serving under the Directorate of Education, GNCT of Delhi, filed this Original Application to challenge an order dated 24.02.2026 that excluded them from promotion to the post of Post Graduate Teacher (Physical Education).

Source reference: p. 3

The applicants sought a direction for the respondents to grant relaxation regarding qualifications/eligibility criteria as per the Recruitment Rules (RRs) notified on 15.07.2016.

Source reference: p. 3

Procedurally, the applicants moved M.A. No. 2120/2026 to join together in the petition, which the Tribunal allowed.

Source reference: p. 3

The applicants had previously submitted representations on 14.11.2025 and 17.12.2025 seeking relaxation under the rules, which remained pending.

Source reference: p. 5
02

Issues

1. Whether the Recruitment Rules governing the post of PGT (Physical Education) empower the respondents to relax educational qualifications for promotion.

Source reference: p. 4-5

2. Whether the Tribunal should direct the competent authority to decide the pending representations of the applicants regarding said relaxations.

Source reference: p. 5-6
03

Law Applied

Rule 5 and Rule 6 of the Recruitment Rules (Notification No. F.DE.2(8)1721E-W2005/2521), which grant the Government the "Power to Relax" any provisions of the rules for any class or category of persons for reasons recorded in writing.

Source reference: p. 4

A specific "NOTE" within the RRs stating that qualifications are relaxable at the discretion of the competent authority for candidates who are otherwise "well qualified".

Source reference: p. 4-5

The application was filed under Section 19 of the Administrative Tribunals Act, 1985.

Source reference: p. 3
04

Reasoning

The Tribunal did note enter into the merits of the applicants' eligibility but focused on the procedural existence of the relaxation clauses within the RRs.

Source reference: p. 4-5

The applicants argued that since the RRs specifically provide for both general power to relax (Rule 5) and specific relaxation of qualifications (Note), the respondents have the legal mandate to consider their grievances.

Source reference: p. 4-5

The Tribunal found that because representations dated 14.11.2025 and 17.12.2025 were already pending before the competent authority, the most appropriate judicial course at the admission stage was to compel the executive to exercise its discretionary power under the stated rules.

Source reference: p. 5-6
05

Holding

The Tribunal held that the competent authority is duty-bound to consider the applicants' request for relaxation in light of the RRs.

The respondents were directed to decide the pending representations [Annexure A/4] by passing a reasoned and speaking order within thirty (30) days of receipt of the certified copy of the order; the O.A. was disposed of at the admission stage without expressing an opinion on the merits.

Source reference: p. 6
CAT - ['Delhi']

Original Court PDF

Dr Anil BalonivsGNCTD

CAT - ['Delhi'] · April 27, 2026

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