Delayed challenge to Tribunal orders regarding administrative inertia in notifying Recruitment Rules warrants no discretionary relief.

The Respondents, Company Prosecutors in the Indian Corporate Law Service (ICLS) under the Ministry of Corporate Affairs, approached the Central Administrative Tribunal (CAT) highlighting stagnation in promotional avenues to the Junior Time Scale (JTS).

Under the ICLS Rules, 2015, promotion is 40%, but no inter se quota exists between feeder cadres like Company Prosecutor and Senior Technical Assistant.

Although draft Recruitment Rules (RRs) with a 4:7 ratio were finalized at the Ministry level by January 2024, they remained unnotified.

On 24.12.2024, the Tribunal directed the Petitioners to notify the RRs within two months, failing which they were to proceed with the draft RRs for future Departmental Promotion Committees (DPCs).

The Union of India challenged this order via a Writ Petition filed in February 2026, over a year after the Impugned Order.

Whether the prolonged administrative delay and subsequent filing of the Writ Petition after one year justifies the exercise of discretionary jurisdiction under Article 226.

Whether the Tribunal’s direction to notify draft RRs or act upon them constitutes judicial overreach or a jurisdictional error.

The court applied the principles governing judicial review under Articles 226 and 227 of the Constitution of India, which limit interference to cases of patent illegality, jurisdictional error, perversity, or manifest arbitrariness.

It further invoked the equitable nature of writ jurisdiction, which may be denied to parties guilty of laches or "prolonged administrative inaction".

The court also referenced the executive's duty to conclude administrative exercises within a reasonable timeframe to prevent service stagnation.

The Court observed that the Petitioners failed to provide a satisfactory explanation for the one-year delay in approaching the Court, dismissing the "moving file" excuse as insufficient and a sign of administrative inertia.

Regarding the merits, the Court found that the Tribunal did not perform a legislative function or amend statutory rules; rather, it merely compelled the executive to finalize a process it had already initiated and draft-finalized at the Ministry level.

Since the executive had ignored prior directions from 2023 regarding employee representations, the Tribunal’s timeline was deemed a necessary measure to ensure a "definitive position" was taken.

The Court emphasized that a party seeking equitable relief under Article 226 cannot do so after allowing a judicial direction to remain unattended for over a year.

It held that there was no jurisdictional error or perversity in the Tribunal's order.

The Court refused to interfere due to the Petitioners' failure to comply with directions for over a year, the resulting stagnation of Group ‘A’ officers, and the fact that the draft rules were already finalized at the Ministry level.

The Tribunal’s order directing notification of the new RRs or implementation of the draft RRs stands.