CAT - Delhi

Dismissal of review application when prior similar case found no error apparent on record.

National Technical Research Organisation v. Dinesh Kumar & Ors. [R.A. No. 75/2025 IN O.A. No.3626/2023 & batch]

CAT - DelhiJUDGMENT: no citation2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The National Technical Research Organisation (Review Applicant) filed Review Application No. 75/2025 concerning O.A. No. 3626/2023 and Review Application No. 80/2025 concerning O.A. No. 4016/2023

Source reference: p.1-2

These applications sought a review of previous orders issued by the Central Administrative Tribunal

Source reference: p.4

The Review Respondents’ counsel placed on record a decision in M.A. No. 4600/2025 in R.A. No. 172/2025 in O.A. No. 3625/2023, decided on November 4, 2025, by a Coordinate Bench, where a similar review application was dismissed for being devoid of merit

Source reference: p.3-4
02

Issues

Whether the delay in filing Review Applications No. 75/2025 and 80/2025 should be condoned

Source reference: p.3

Whether there is an error apparent on the face of the record warranting review of the final order dated April 22, 2024, in O.A. No. 3625/2023, the underlying original application for which the review was sought

Source reference: p.4

Whether the present Review Applications (R.A. No. 75/2025 and R.A. No. 80/2025) should be dismissed based on the precedent set by a Coordinate Bench in a similar matter

Source reference: p.4
03

Law Applied

The Tribunal applied the principle that delay in filing review applications can be condoned for sufficient reasons, as implicitly demonstrated by the allowance of Miscellaneous Application No. 1815/2025 and No. 1922/2025

Source reference: p.3

The primary rule for review applications is that a review is warranted only if there is an "error apparent on the face of the record," and not merely a repetition of arguments already considered and dealt with in the original proceedings

Source reference: p.4

Furthermore, the principle of stare decisis or judicial consistency in similar matters by Coordinate Benches was also considered

Source reference: p.3, p.4
04

Reasoning

The Tribunal first condoned the delay in filing the Review Applications, stating "For the reasons mentioned in the Miscellaneous Application, we allow the same and condone the delay..."

Source reference: p.3

Regarding the merits of the review, the Tribunal adopted the reasoning from a decision by a Coordinate Bench in M.A. No. 4600/2025 in R.A. No. 172/2025 in O.A. No. 3625/2023, dated November 4, 2025

Source reference: p.3-4

In that precedent, the Coordinate Bench found "no error apparent on the face of the record warranting review," concluding that the "contentions raised in the review application are, in essence, a repetition of the arguments already considered and dealt with in the original proceedings"

Source reference: p.4

Since the present matters were deemed "identical in nature" and involved "similar grounds", the Tribunal applied the same reasoning, concluding that no error apparent on the face of the record existed in the present case

Source reference: p.3, p.4
05

Holding

The Tribunal allowed M.A. No. 1815/2025 and M.A. No. 1922/2025, thereby condoning the delay in filing Review Applications No. 75/2025 and R.A. No. 80/2025

However, based on the precedent set by a Coordinate Bench and finding no error apparent on the face of the record, the Tribunal dismissed Review Application No. 75/2025 and Review Application No. 80/2025

Source reference: p.4

All pending M.A.s, if any, also stood disposed of, with no order as to costs

Source reference: p.4
CAT - Delhi

Original Court PDF

National Technical Research Organisation v. Dinesh Kumar & Ors. [R.A. No. 75/2025 IN O.A. No.3626/2023 & batch]

CAT - Delhi · no citation

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment