CAT - ['Delhi']
Employment and Labour LawAdministrative and Public Law

Failure to separately adjudicate an applicant’s eligibility does not constitute an error apparent warranting review.

Bhanu Priya vs DSSSB & ORS.

CAT - ['Delhi']JUDGMENT: September 30, 20262 MIN READSOURCE JUDGMENT
Failure to separately adjudicate an applicant’s eligibility does not constitute an error apparent warranting review.. Bhanu Priya vs DSSSB & ORS.. CAT - ['Delhi']. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

Bhanu Priya sought review of the common order dated 30 July 2026 in O.A. No. 964/2023 and connected matters, including her O.A. No. 2594/2023.

Source reference: para. 1

She argued that the Tribunal had not specifically adjudicated her eligibility, although the order recorded that she held a B.A. (Hons.) from the University of Delhi and had studied Hindi in the first and second years of graduation.

Source reference: paras. 2–3

She also relied on a certificate dated 2 September 2022 from Ramjas College and judgments she said had not been considered.

Source reference: paras. 4–5
02

Issues

Whether the Tribunal’s failure to separately address the review applicant’s individual eligibility or submissions constituted an error apparent on the face of the record warranting review.

Source reference: paras. 2–3

Whether reconsidering the applicant’s Hindi studies, college certificate and eligibility under the Recruitment Rules would fall within the limited scope of review.

Source reference: paras. 4–5
03

Law Applied

The Tribunal applied the principle that review is confined to correcting an error apparent on the face of the record or another recognised ground for review; it is not an appeal or a rehearing on the merits.

Source reference: paras. 3–5

A request requiring fresh examination of evidence, qualifications or the application of material already on record does not, by itself, justify review.

Source reference: paras. 3–5

The order identifies no specific statutory provision or precedent as the basis for this principle.

Source reference: paras. 3–5
04

Reasoning

The Tribunal found that the original order had considered the Recruitment Rules, the appended Note, the applicants’ qualifications and the governing legal position, and had specifically recorded the review applicant’s qualifications in a comparative table.

Source reference: para. 3

The fact that each submission or document was not discussed separately did not establish an apparent error.

Source reference: paras. 3–5

Determining whether her Hindi studies and the Ramjas College certificate satisfied the Recruitment Rules would require a fresh examination of her qualifications and eligibility, which would amount to a merits rehearing.

Source reference: paras. 4–5

Her complaint about the treatment of cited judgments likewise did not establish a patent error.

Source reference: paras. 4–5
05

Holding

The Tribunal held that no error apparent on the face of the record or other ground for review had been established.

It dismissed the Review Application, disposed of any pending miscellaneous applications and made no order as to costs.

Source reference: para. 7
CAT - ['Delhi']

Original Court PDF

Bhanu PriyavsDSSSB & ORS.

CAT - ['Delhi'] · September 30, 2026

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