CAT - ['Delhi']

Direction to administrative authorities to decide pending service representations through a reasoned and speaking order.

Madan lal vs HEALTH AND FAMILY WELFARE

CAT - ['Delhi']JUDGMENT: April 13, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, a Chief Medical Officer (NFSG) serving under the Directorate of Health Services, Government of NCT of Delhi, filed an Original Application (O.A.) seeking the release of Conveyance Allowance (CA) arrears from July 1, 2017, to the present, amounting to ₹12,81,969/-

Source reference: p. 2

The applicant alleged that the respondents failed to grant the allowance despite Office Memorandums (OMs) dated 19.07.2017 and 01.12.2021, and further challenged objections raised regarding log-book maintenance

Source reference: p. 2

Between April 2023 and July 2025, the applicant submitted eleven representations to the authorities, which remained undecided

Source reference: p. 3-4

During proceedings, the applicant limited the prayer to seeking a direction for the respondents to decide these pending representations within a specific timeframe

Source reference: p. 3
02

Issues

Whether the respondents' inaction in deciding the applicant's multiple representations regarding the grant of Conveyance Allowance warrants a direction for a time-bound disposal

Source reference: p. 4
03

Law Applied

The Tribunal relied on the principles of natural justice and the administrative requirement to pass reasoned and speaking orders on employee grievances

Source reference: p. 4

the claim was based on O.M. No. 45013/01/2021-CHS-V dated 01.12.2021 and O.M. dated 19.07.2017, which regulate the entitlement and procedural prerequisites for Conveyance Allowance for medical officers under the Central Health Service (CHS) framework

Source reference: p. 2
04

Reasoning

The Tribunal refrained from adjudicating the merits of the applicant’s entitlement to the allowance or the validity of the respondents' objections regarding log-book verification

Source reference: p. 5

It observed that the applicant had a legitimate expectation of a response to his various representations submitted over two years

Source reference: p. 4

Given the respondents' concession that the representations could be considered in accordance with the law, the Tribunal determined that the principles of natural justice necessitated a formal administrative decision

Source reference: p. 4

The Tribunal underscored that the competent authority must pass a "reasoned and speaking order" to ensure transparency and allow for further judicial review if necessary

Source reference: p. 5
05

Holding

The Tribunal disposed of the O.A. at the admission stage

It directed the respondents to decide the applicant's pending representations (dated 18.04.2023, 03.07.2023, 15.11.2023, 02.03.2024, 15.04.2024, 28.08.2024, 29.11.2024, 18.02.2025, 29.05.2025, and 30.07.2025) by passing a reasoned and speaking order within four weeks from the receipt of the order

Source reference: p. 4-5

It further ordered that if the decision is favorable, the arrears shall be disbursed; if unfavorable, the applicant retains the liberty to challenge the fresh order

Source reference: p. 5

No costs were awarded

Source reference: p. 5
CAT - ['Delhi']

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Madan lalvsHEALTH AND FAMILY WELFARE

CAT - ['Delhi'] · April 13, 2026

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