Courts should adopt a pragmatic approach and examine merits where delayed claims challenge termination.

The petitioner was appointed as a Commercial-cum-Ticket Clerk under the Sports Quota.

His appointment was based on a bronze medal allegedly won in a Junior Body Building competition.

The Railway authorities alleged that he had suppressed his age to secure the appointment and, after issuing a charge-sheet and show-cause notice, terminated him from service.

The petitioner challenged the termination before the Central Administrative Tribunal, Madras Bench, along with an application for condonation of delay.

The CAT dismissed the condonation application on the ground that the Original Application had been filed with a delay of 964 days, and did not examine the merits of the termination.

The petitioner contended that his distressed condition and the COVID-19 pandemic prevented him from approaching the Tribunal earlier, whereas the respondents argued that the delay continued even after the pandemic period and was not adequately explained.

1. Whether the CAT was justified in dismissing the petitioner’s application solely on the ground of a 964-day delay without examining the merits of his challenge to the termination.

2. Whether, in the circumstances of a termination from service, the matter ought to be remanded to the CAT for adjudication on merits despite the delay.

The Court applied Section 21 of the Administrative Tribunals Act, 1985, which prescribes limitation for applications before the Tribunal and permits condonation of delay upon sufficient cause.

It reiterated that unexplained and unreasonable delay ordinarily cannot be condoned, whereas a reasonable delay may be condoned by adopting a pragmatic approach.

The Court relied on Inder Singh v. State of Madhya Pradesh, 2025 INSC 382, for the principle that although delay cannot be condoned without sufficient cause, merits should not be scuttled merely on the basis of limitation where the circumstances warrant examination of the substantive dispute.

It further applied the principle that, particularly in cases involving termination from service—described as “civil death”—courts should consider the genuineness of the claim and adjudicate the dispute on merits rather than dismissing it solely on delay.

The Court acknowledged that the petitioner’s explanation based solely on the COVID-19 pandemic was insufficient, since the pandemic had ended in 2021 whereas the application was filed in 2024, resulting in a delay of 964 days.

However, the CAT had dismissed the proceedings at the threshold and had not considered the legality of the petitioner’s termination or the allegations of age suppression on merits.

Given that the challenge concerned termination from service and that dismissal by the CAT would leave the petitioner without an effective alternative forum, the Court held that a rigid approach to delay was inappropriate in the circumstances.

The proper course was to permit the Tribunal to consider the substantive dispute, while leaving all merits—including the respondents’ allegations—to be decided by the CAT in accordance with law.

The matter was remanded to the CAT with directions to take the Original Application on file, number it, hear the parties, and dispose of it on merits and in accordance with law as expeditiously as possible.

No order as to costs was made.