Every administrative or quasi-judicial order must contain specific reasons to ensure valid judicial review.

The applicant, a Director at RDSO Lucknow, challenged his performance assessment of ‘Good’ for the year 2013-14.

This grading was significantly lower than his previous and subsequent ratings of ‘Very Good’ and ‘Outstanding’.

During this period, the Railway Board revised the benchmark for promotion to Non-Functional Senior Administrative Grade (NFSAG), making 'Good' a below-benchmark grade.

The applicant's representation dated 12.12.2014 was rejected by Respondent No. 2 via a brief order on 09.03.2015.

A subsequent appeal was rejected on 26.05.2016 on the grounds that no provision for a second representation existed.

The applicant contended the rejection was non-speaking and violated procedural norms.

1. Whether the order dated 09.03.2015, rejecting the applicant’s representation against his APAR grading, was legally sustainable as a reasoned and speaking order.

2. Whether the respondents were required to dispose of the representation in a quasi-judicial manner following DoPT guidelines and judicial precedents.

The Tribunal applied the fundamental administrative law principle that "reason is the heartbeat of an order".

It relied on the Supreme Court precedent Basudev Datta vs The State of West Bengal Ors (2024 INSC 940), which mandates that every administrative or quasi-judicial order must contain reasons to ensure the authority applied its mind and to allow for judicial review.

Reference was also made to the DoPT Office Memorandum dated 31.01.2014, stipulating the disposal of APAR representations in a quasi-judicial manner.

The Tribunal examined the rejection order dated 09.03.2015 and found that Respondent No. 2 had merely stated he found "no merit" after reviewing the documents, without providing specific reasons for upholding the 'Good' grade.

The court reasoned that since the 'Good' grade now acted as a bar for promotion to NFSAG due to revised benchmarks, the representation required a higher standard of scrutiny.

The failure to assign specific reasons rendered the order "cryptic" and "summary," making it impossible for a judicial authority to test its correctness or verify the application of mind.

Consequently, both the initial rejection and the subsequent refusal to hear the appeal were found to be unsustainable in law.

It directed the respondents to reconsider the applicant’s representation dated 12.12.2014 and issue a reasoned and speaking order within two months.

The respondents were further directed that if the representation is decided in the applicant's favor, they must consider granting him SAG (NF) status from the original due date with all consequential benefits.