Quasi-judicial authorities become functus officio upon communication of final orders, precluding subsequent modifications without express statutory authority.

The applicant, a former Section Officer, was subjected to disciplinary proceedings under Rule 14 of the CCS (CCA) Rules, 1965, resulting in his removal from service in 2009

In a previous round of litigation (OA No. 462/2010), the Tribunal found the penalty disproportionate and remanded the matter

Consequently, the respondents issued an order dated April 17, 2012, modifying the penalty to "Compulsory Retirement," explicitly stating this would allow the applicant to avail terminal benefits

However, through subsequent orders dated September 30, 2015, and March 8, 2017, the respondents "interpreted" and modified the 2012 order to restrict benefits to 75% pension and full gratuity, rather than full terminal benefits

The applicant challenged these subsequent modifications, arguing the authority became functus officio after the 2012 order was communicated

1. Whether the disciplinary authority became functus officio after passing and communicating the penalty modification order dated April 17, 2012

2. Whether the respondents had the legal authority to subsequently curtail the terminal benefits of the applicant in the absence of an express power of review under the relevant service rules

The court primarily applied the doctrine of functus officio, as elucidated by the Supreme Court in State Bank of India and Others v. S. N. Goyal (2008), which establishes that a quasi-judicial authority cannot review its own decision once it is pronounced, published, or communicated, unless the relevant statute expressly permits such a review

The court also referred to Rule 40(1) of the CCS (Pension) Rules, 1972, regarding the grant of pension and gratuity upon compulsory retirement

The Tribunal observed that the order dated April 17, 2012, passed in the name of the President of India, was a final decision intended to grant the applicant terminal benefits that are otherwise denied in cases of removal

The court noted that once this order was notified and communicated, the authority fulfilled its function and possessed no further power to alter the decision

The respondents failed to produce any specific provision under the CCS (CCA) Rules or CCS (Pension) Rules that permitted a review or modification of a final penalty order years after its issuance

The Tribunal found that the 2015 and 2017 orders, which attempted to reinterpret the 2012 order to curtail benefits, were not in consonance with the original intent and were issued in a casual manner without proper application of mind

The court held that the respondents could not legally modify the 2012 order after becoming functus officio

The respondents were directed to release all withheld terminal benefits and consequential dues within three months, failing which the amount would carry an interest rate of 7.1%

Additionally, the Tribunal imposed a token cost of Rs. 10,000 on Respondent No. 1 for causing avoidable and repetitive litigation