CAT - Delhi

English versions of examination questions prevail by common practice despite the absence of specific written instructions.

Geeta vs COMM. OF POLICE

CAT - DelhiJUDGMENT: March 20, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Review Applicants, Constables in the Delhi Police, sought a review of the Tribunal's order dated 03.02.2026, which had dismissed their Original Application (OA No. 4708/2015)

Source reference: p. 2

The applicants contended that the Tribunal committed an error apparent on the face of the record by relying on an instruction (Para 15) from a test booklet which stated that the English version of questions would prevail over the Hindi version in case of variation

Source reference: p. 2

They asserted that this specific instruction did not exist in the 2014 examination booklet they used, but pertained to a subsequent year’s examination

Source reference: p. 2

The applicants argued that reliance on a document from a different year led to an erroneous finding

Source reference: p. 2
02

Issues

1. Whether the reliance on an instruction from a subsequent year’s test booklet constitutes an "error apparent on the face of record" warranting a review under Section 22(3)(f) of the Administrative Tribunals Act, 1985

Source reference: p. 3-4

2. Whether the "common practice" of the English version prevailing in examination disputes justifies the dismissal of the OA despite the absence of a specific instruction in the relevant year's booklet

Source reference: p. 3
03

Law Applied

The Tribunal applied Section 22(3)(f) of the Administrative Tribunals Act, 1985, and Rule 17 of the CAT (Procedure) Rules, 1987, regarding review jurisdiction

Source reference: p. 2

It relied on the Supreme Court’s ruling in State of West Bengal v. Kamal Sengupta (2008), which established that review is limited to correcting errors apparent on the face of the record and prohibits the re-appreciation of evidence

Source reference: p. 3-4

It further cited Union of India v. Tarit Ranjan Das (2004), holding that a review cannot be treated as an appeal in disguise or a fresh hearing for new arguments

Source reference: p. 4
04

Reasoning

The Tribunal acknowledged that the specific instruction regarding the English version prevailing was not present in the 2014 test booklet but appeared in subsequent years

Source reference: p. 3

However, the Tribunal reasoned that its original decision was based on "common knowledge and past practice," asserting that English versions traditionally prevail in competitive exams

Source reference: p. 3

The Bench noted that the issue of variation between Hindi and English versions had been specifically considered during the initial adjudication of the OA

Source reference: p. 4

It determined that the Review Application was essentially an attempt to re-argue the merits of the case and seek a re-appreciation of facts, which falls outside the narrow scope of review jurisdiction

Source reference: p. 4-5

The Tribunal emphasized that even if an alternative view were possible, it does not constitute a patent error warranting interference

Source reference: p. 4
05

Holding

The Tribunal dismissed the Review Application

It held that the grounds urged did not disclose any patent error or mistake apparent on the face of the record

Source reference: p. 4

The Court affirmed that the English version shall prevail based on reasoning and common practice, and concluded that the matter deserved a "quietus and decent burial" due to its age

Source reference: p. 3-5
CAT - Delhi

Original Court PDF

GeetavsCOMM. OF POLICE

CAT - Delhi · March 20, 2026

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