Day-to-day administrative powers do not confer authority to review disciplinary penalties.

The respondent, a DTC driver, was charged with conniving with a conductor and duty officer in relation to bus tickets.

The Inquiry Officer partly proved the charges, and the Disciplinary Authority imposed a penalty of reprimand on 25 May 2015.

On 16 January 2016, the Regional Manager withdrew that penalty, acting on a direction to review it, and issued a show-cause notice proposing dismissal.

The respondent challenged the Regional Manager’s authority before the Central Administrative Tribunal; after a further inquiry, he was dismissed on 30 January 2016.

The Tribunal set aside the dismissal, holding that the Regional Manager lacked power to review the Disciplinary Authority’s decision. DTC challenged that judgment.

1. Whether Section 12(1)(c) of the Road Transport Corporations Act, 1950 authorised the Managing Director to review the Disciplinary Authority’s penalty decision.

2. Whether the Regional Manager could exercise such review power under the delegation made by Office Order No. 4 dated 15 April 1997.

Section 12(1)(c) of the Road Transport Corporations Act, 1950 authorises the Board to empower the Managing Director or another officer to exercise powers and perform duties necessary for the Corporation’s efficient day-to-day administration; it does not, by itself, confer a power to review a quasi-judicial disciplinary decision.

Section 12(2) permits the Chairman, Vice-Chairman or Managing Director to delegate their powers to an officer, but a delegate cannot receive a power the delegating authority does not possess.

A review power must be conferred by law; no authority has an inherent power of review. The Court referred to State of West Bengal v. Jai Hind (P) Ltd., (2026) 5 SCC 481.

Although Office Order No. 4 delegated the Managing Director’s powers to Regional Managers, that delegation could not supply a review power absent in the Managing Director.

The Court construed Section 12(1)(c) as concerning day-to-day administration, not the review of a Disciplinary Authority’s quasi-judicial decision.

Nor could the Vigilance Department authorise the Managing Director to exercise a power not vested in him by law.

Consequently, the Regional Manager’s withdrawal of the reprimand exceeded his lawful authority, and the Tribunal’s decision was not liable to interference.

It dismissed DTC’s writ petition in limine and directed that the respondent’s retiral benefits be disbursed within four weeks.