Medal-Winning Railway Employee’s Increment Claim: CAT Rejects Review, Leaves Direction to Consider Payment Intact

The respondent, appointed as a Ticket Collector under the sports quota in 1996, sought additional sports-incentive increments for athletic achievements in 1997–1999 under a Railway Board circular dated 20 June 2006.

The Tribunal allowed his O.A. on 19 January 2026, directing consideration of admissible increments and consequential benefits, principally on parity with another railway employee, Sh. Tejinder Pal Singh.

The Union and the Divisional Railway Manager challenged that order before the Delhi High Court, but withdrew the writ petition on 13 August 2026 with liberty to seek review.

They then sought review under Section 22(3)(f) of the Administrative Tribunals Act, 1985 and Rule 17 of the CAT (Procedure) Rules, 1987, accompanied by an application to condone a 212-day delay.

They argued that the Tribunal had overlooked limitation, the absence of an RSPB recommendation, a five-increment ceiling under the 2010 policy, and distinctions from the comparator’s case.

Whether the review applicants established a ground for review under Section 22(3)(f) of the Administrative Tribunals Act, 1985 and Order XLVII Rule 1 CPC.

Whether the Tribunal’s treatment of the review applicants’ arguments on limitation, RSPB recommendation, the five-increment ceiling, and parity disclosed an error apparent on the face of the record or otherwise justified review.

Whether the 212-day delay in filing the Review Application should be condoned.

Section 22(3)(f) of the Administrative Tribunals Act, 1985, Rule 17 of the CAT (Procedure) Rules, 1987, and Order XLVII Rule 1 CPC confine review to limited grounds, including discovery of new and important matter or evidence, an error apparent on the face of the record, or another sufficient reason.

An error apparent must be self-evident and not require extended reasoning; review cannot be used as an appeal or to rehear the merits or replace one plausible view with another.

The Tribunal relied on Parsion Devi v. Sumitri Devi, (1997) 8 SCC 715; Lily Thomas v. Union of India, (2000) 6 SCC 224; State of West Bengal v. Kamal Sengupta, (2008) 8 SCC 612; and Union of India v. Tarit Baran Dey, (1998) 8 SCC 481, for these principles.

The Tribunal found that the grounds raised in review—including limitation, the absence of an RSPB recommendation, the 2010 policy ceiling, and the claimed distinction from Sh. Tejinder Pal Singh—had already been pleaded and were available when the O.A. was decided.

The original bench had sought an additional affidavit on the comparator and had considered the relevant service and administrative records before granting relief on parity and non-discrimination grounds.

The review applicants’ objections therefore sought reconsideration of the merits, rather than identifying new material or a patent error.

The Tribunal held that such arguments belonged before an appellate forum, not in review.

It gave no separate substantive analysis of the delay-condonation application, dismissing it along with the Review Application.

It dismissed the Review Application and the pending application to condone the 212-day delay, with no order as to costs.