CAT - Kolkata

Mandatory consideration of Fixed Medical Allowance parity for civilian employees under Central Services (Medical Attendance) Rules.

Raja Bhowal vs DEFENCE

CAT - KolkataJUDGMENT: March 12, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The 155 applicants are Group-C civilian employees (including Senior Material Assistants, Tradesman Mates, and Firemen) serving at the 16 Field Ammunition Depot (FAD) under the Ministry of Defence

Source reference: p. 7

The applicants alleged that their Fixed Medical Allowance (FMA) was illegally stopped effective January 2011 based on a Ministry of Health Family Welfare Office Memorandum dated 03.06.2015

Source reference: p. 9, para 3(c), 6

They claimed entitlement to medical benefits under the Central Services (Medical Attendance) Rules, 1944

Source reference: p. 8, para 3(b)

The applicants asserted they are similarly situated to the litigants in O.A./350/0191/2019, where the Tribunal granted relief that was subsequently implemented by the department in July 2025

Source reference: p. 9-10, para 7

They submitted a joint representation on 30.07.2025, which remained pending

Source reference: p. 10, para 8
02

Issues

1. Whether the applicants are entitled to the restoration and payment of Fixed Medical Allowance (FMA) with effect from January 2011 in accordance with the Central Services (Medical Attendance) Rules, 1944

Source reference: p. 8-9, para 3

2. Whether the applicants are entitled to parity with the judgment delivered in O.A./350/0191/2019

Source reference: p. 9-10, para 7
03

Law Applied

The court primarily applied the Central Services (Medical Attendance) Rules, 1944, which govern the medical benefits and allowances for central government civilian employees

Source reference: p. 8, para 3(b)

It further relied on Section 19 of the Administrative Tribunals Act, 1985, regarding the maintainability of applications

Source reference: p. 8, para 3

Rule 4(5)(a) of the CAT (Procedure) Rules, 1987, regarding joint prosecution

Source reference: p. 9, para 4

the principle of parity was invoked based on the Tribunal's previous order in O.A. 191/2019, which established the right to FMA for similarly situated employees

Source reference: p. 9-10, para 7
04

Reasoning

The Tribunal observed that the core grievance involved the arbitrary stoppage of FMA and the demand for parity with a previously decided and implemented matter (O.A. 191/2019)

Source reference: p. 9-10, para 7

The Single Bench, acting under Section 5(6) of the Administrative Tribunals Act, 1985, determined that no complicated questions of law were involved

Source reference: p. 8, para 1

Consequently, the Tribunal found that inviting a formal reply from the respondents would serve no "fruitful purpose" and would cause unnecessary delay

Source reference: p. 10, para 9

The court reasoned that the administrative authorities must first evaluate the applicants' pending representation in the context of existing statutory rules and the specific judicial precedents cited by the applicants

Source reference: p. 10, para 8, 10
05

Holding

The Tribunal allowed the Miscellaneous Application for joint prosecution

the Tribunal disposed of the matter by directing the respondents to consider the applicants' joint representation dated 30.07.2025

Source reference: p. 10, para 10

The respondents were ordered to treat the O.A. as part of the representation and pass a reasoned order within 90 days of receipt of the court’s order

Source reference: p. 10, para 10

No costs were awarded

Source reference: p. 10, para 11
CAT - Kolkata

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Raja BhowalvsDEFENCE

CAT - Kolkata · March 12, 2026

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