Courts cannot moderate or reassess the merit and grading of an employee's APAR under judicial review.

The applicant, a Deputy Chief Material Manager in the Indian Railways who joined through the UPSC Engineering Services Examination, challenged his Annual Performance Appraisal Report (APAR) grading for the year 2017–18

While the Reporting Officer had assigned a grading of 9.45, the Reviewing Officer downgraded it to 4.19 ("Good"), which was subsequently accepted by the Accepting Authority

The applicant submitted a representation on December 31, 2018, seeking an upgrade, which was rejected by the competent authority on December 12, 2019, on the grounds that no new facts were brought forward to merit a revision

The applicant then approached the Tribunal seeking to quash the rejection order and the 2017–18 APAR

1. Whether the Tribunal, under the power of judicial review, can moderate or reassess the merit and grading of an officer’s APAR

2. Whether the respondents committed any procedural infirmity in the recording and finalization of the applicant's APAR and the subsequent rejection of his representation

Courts and Tribunals cannot moderate or reassess the appraisal and grading of an officer for a particular year, as judicial review does not extend to substituting the Court's assessment for that of the competent authorities

administrative procedures governing APARs, which involve a five-stage process: personal data entry, self-appraisal, assessment by the reporting authority, review by the reviewing authority (with reasons for disagreement), and final remarks by the accepting authority

The Tribunal observed that the Reviewing Authority had exercised its jurisdiction to disagree with the Reporting Authority’s assessment of 9.45 and recorded its own assessment of 4.19

This assessment was duly accepted by the next higher authority (the Accepting Authority)

The Tribunal noted that the APAR process was procedurally sound, as the applicant was given the opportunity to represent against the grading

Upon perusing the rejection order dated December 12, 2019, the Tribunal found that the competent authority had actively considered the representation but upheld the original assessment because the applicant failed to introduce new facts

Applying the S.L. Chhabra precedent, the Tribunal reasoned that the Reviewing Authority is the body legally competent to evaluate work performance, and it is not the role of the judiciary to reassess an officer’s performance or "moderate" the assigned points

The Tribunal answered the issues in the negative, holding that the grading finalized by the superior authorities stands

Consequently, the Original Application was dismissed, all related Miscellaneous Applications were disposed of, and any interim orders were discharged