Repeated representations cannot revive limitation for concluded promotion orders.

The applicant challenged promotion orders dated 5 April 2011, 31 March 2016 and 17 March 2022, alleging that his promotions were delayed because his CAPARs/APARs were not assessed during sanctioned study leave

He stated that he had pursued the grievance through representations since 2011 and that a departmental committee had examined it; after a further representation dated 3 December 2025, he filed the Original Application on 27 January 2026

He sought condonation of delay, relying on the continuing nature of the grievance and the Supreme Court’s limitation-exclusion orders

The respondents opposed condonation, contending that the challenge to the old promotion orders was time-barred and that representations could not revive the cause of action

1. Whether the applicant established sufficient cause to condone the delay in filing the Original Application challenging the promotion orders

2. Whether repeated representations, the committee’s consideration of the grievance, or the alleged continuing effects of the promotion orders extended or revived the limitation period

3. Whether the limitation period excluded pursuant to the Supreme Court’s suo motu proceedings rendered the challenge to the earlier promotion orders timely

Section 21 of the Administrative Tribunals Act, 1985 governs the period of limitation for applications before the Tribunal

Repeated representations or administrative consideration do not, by themselves, extend the statutory limitation period or revive a stale cause of action

A concluded service order does not become a continuing cause of action merely because it has continuing financial or service consequences; Union of India v. Tarsem Singh, (2008) 8 SCC 648, concerns continuing wrongs and recurring benefits but does not permit the reopening of concluded promotion orders in the circumstances of this case

The limitation period excluded under the Supreme Court’s orders in In Re: Cognizance for Extension of Limitation, Suo Motu Writ Petition (C) No. 3 of 2020, was also considered

The Tribunal found that the applicant knew of the alleged promotion grievance from 2009 and was aware of the subsequent promotion orders when they were issued, but approached the Tribunal only in January 2026

His representations and the committee process did not stop limitation or revive the challenge, particularly since the committee report had been submitted in 2021 and was within his knowledge

The orders were specific, concluded decisions; their alleged continuing effects did not make the claims continuing causes of action under Tarsem Singh

Even after applying the Supreme Court’s exclusion of the relevant period, the delay in challenging the 2011 and 2016 orders remained unexplained

It dismissed the Miscellaneous Application for condonation and, consequently, dismissed the Original Application as barred by limitation and delay and laches. No order as to costs was made