CAT - ['Delhi']

Direction to Decide Pending Representation for Issuance of No Objection Certificate for Passport in Time-Bound Manner

Dr Vandana Bagga vs GNCTD

CAT - ['Delhi']JUDGMENT: May 11, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, aged 61, is currently serving as the Director of the Directorate of Family Welfare, Government of NCT of Delhi

Source reference: p. 1-2

She approached the Central Administrative Tribunal (CAT), Principal Bench, seeking a mandatory injunction against the respondents for the issuance of a "No Objection Certificate" (NOC) required for her passport application

Source reference: p. 2

The applicant had previously submitted a representation dated 24.11.2025 (Annexure/A-3) to the authorities, which remained pending

Source reference: p. 3

During the hearing, the applicant’s counsel limited the prayer to a request for a time-bound disposal of the said representation

Source reference: p. 3
02

Issues

1. Whether the Tribunal should direct the respondents to decide the applicant's pending representation regarding the issuance of an NOC for a passport within a specific timeframe?

Source reference: p. 3, para. 4, 6
03

Law Applied

The court exercised jurisdiction under Section 19 of the Administrative Tribunals Act, 1985, which empowers the Tribunal to adjudicate disputes regarding the recruitment and conditions of service of public servants

Source reference: p. 2, para. 1

The court also noted the applicant's reliance on Ministry of External Affairs Office Memorandum No. VI/401/01/05/2014 dated 26.05.2014, which outlines the procedure for issuing NOCs to government employees for passport services, and the fundamental rights to travel and liberty guaranteed under Articles 19 and 21 of the Constitution of India

Source reference: p. 2, para. 1-2
04

Reasoning

The Tribunal avoided examining the merits of the case, focusing instead on the procedural delay in addressing the applicant's administrative grievance

Source reference: p. 3, para. 6

Since the applicant's counsel expressed satisfaction with a direction for a reasoned and speaking order on the pending representation, the Tribunal determined that the principles of natural justice would be satisfied by compelling the competent authority to act within a fixed period

Source reference: p. 3, para. 4, 6

The Tribunal emphasized that this direction does not reflect an opinion on the merits, leaving the respondents free to decide the matter in accordance with existing law

Source reference: p. 3-4, para. 7
05

Holding

The Tribunal disposed of the O.A. at the admission stage by directing the competent authority among the respondents to consider and decide the applicant's representation dated 24.11.2025

The respondents are ordered to pass a reasoned and speaking order within four weeks from the receipt of the certified copy of the order and communicate the decision to the applicant immediately thereafter

Source reference: p. 3, para. 6

No costs were awarded

Source reference: p. 4, para. 10
CAT - ['Delhi']

Original Court PDF

Dr Vandana BaggavsGNCTD

CAT - ['Delhi'] · May 11, 2026

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