CAT - ['Delhi']

Judicial review does not extend to adjudicating disputed questions of fact requiring detailed evidentiary analysis.

Vipin Kumar vs GNCTD

CAT - ['Delhi']JUDGMENT: April 16, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, a Post Graduate Engineer, worked at the Bureau of Indian Standards (BIS) from December 2015 to May 2019

Source reference: p. 2

He applied for the post of Senior Scientific Assistant (Document) in the Forensic Science Laboratory (FSL) under DSSSB Advertisement No. 03/2020, which required two years of experience in analytical methods/research

Source reference: p. 3

While he was declared successful, his initial experience certificate did not specify his duties

Source reference: p. 3

An informal email from BIS in March 2024 claimed his duties included "analytical methods," but FSL rejected this as it was not on official letterhead

Source reference: p. 3

Subsequently, BIS issued an official certificate in June 2024 which omitted the "analytical methods" description

Source reference: p. 4, 8

Following litigation in the Delhi High Court (W.P. No. 3145/2025 and C.P. No. 538/2025), BIS clarified via letter dated May 26, 2025, that the previous email was "overstated," "null and void," and that the June 2024 certificate correctly reflected his actual duties

Source reference: p. 5, 6

Consequently, FSL cancelled the applicant’s candidature on May 15, 2025

Source reference: p. 6
02

Issues

1. Whether the FSL’s rejection of the applicant’s candidature was arbitrary or illegal given the conflicting experience documents provided by BIS

Source reference: p. 9, para. 26

2. Whether the Tribunal, under its power of judicial review, can adjudicate disputed questions of fact regarding the specific nature of duties performed by an employee

Source reference: p. 9, para. 23; p. 10, para. 25
03

Law Applied

Section 19 of the Administrative Tribunals Act, 1985

Source reference: p. 2

the established principle that the power of judicial review does not extend to adjudicating disputed questions of fact that require a detailed evidentiary analysis, such as the examination and cross-examination of witnesses, which is characteristic of a civil trial

Source reference: p. 10, para. 24-25
04

Reasoning

The Tribunal observed that the employer (FSL) acted based on the final clarification provided by the applicant's former employer (BIS).

Source reference: p. 6, 8

BIS explicitly retracted the email that supported the applicant’s eligibility, stating it contained "overstatements" and was "null and void," while affirming that the official letterhead certificate—which lacked the required "analytical methods" experience—was the only relevant document

Source reference: p. 6, 8

The Tribunal reasoned that the applicant's assertion (that he had indeed performed analytical duties despite the certificate's silence) constitutes a claim for a declaration of status

Source reference: p. 9

Because resolving this discrepancy would necessitate a trial-like evaluation of evidence to determine the truth of the applicant's daily work history, it falls outside the scope of judicial review

Source reference: p. 10

The Tribunal found no perversity in FSL's reliance on the official certification of the previous employer to determine eligibility

Source reference: p. 10, para. 26
05

Holding

The Tribunal answered the issues in the negative and dismissed the Original Application

the FSL's decision to reject the candidature was neither illegal nor arbitrary as it was based on the clarification from BIS

Source reference: p. 10

The Tribunal further held it cannot resolve disputed factual claims regarding job duties in a summary proceeding

Source reference: p. 10

No order was made as to costs

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

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Vipin KumarvsGNCTD

CAT - ['Delhi'] · April 16, 2026

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