CAT - ['Allahabad']

Replacement Panel Utilization Rights Lapse Upon Panel Expiry and Prior Judicial Dismissal on Limitation

VIJAY KUMAR vs NORTH EASTERN RAILWAY

CAT - ['Allahabad']JUDGMENT: May 15, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The 35 applicants applied for Group ‘D’ posts in North Eastern Railway under Advertisement No. NER/RRC/D/2007/1 dated 06.12.2007

Source reference: p. 5

Although the applicants cleared the Physical Efficiency Test, written exam, and medical test, they were not appointed because their merit was lower than the last selected candidate

Source reference: p. 6, 11

The applicants alleged that the respondents illegally reduced/surrendered 500 vacancies (Trackman posts) midway through the process

Source reference: p. 8, 11

The applicants had previously filed an OA (Diary No. 03196/2019) which was dismissed as time-barred, a decision later upheld by the Allahabad High Court in Writ A No. 14610 of 2020 on 06.01.2021

Source reference: p. 13-15

The applicants filed the present OA seeking appointment based on a new Railway Board Circular, RBE No. 30/2022

Source reference: p. 4-5
02

Issues

1. Whether the issuance of RBE No. 30/2022 creates a fresh cause of action for candidates from a 2007 recruitment cycle whose previous claims were already dismissed as time-barred.

Source reference: p. 13

2. Whether the applicants are entitled to appointment against unfilled or surrendered vacancies after the expiry of the selection panel’s currency.

Source reference: p. 12-14
03

Law Applied

The Tribunal applied the principle of res judicata and the finality of litigation regarding time-barred claims

Source reference: p. 14

RBE No. 30/2022 dated 15.03.2022, which stipulates that replacement panels can only be utilized during the currency of the panel and when no fresh panel is available

Source reference: p. 14

Dinesh Kumar Kashyap v. South East Central Railway (2019) 12 SCC 798, noting that benefits of such judgments are typically restricted to those who approached the court within a reasonable timeframe

Source reference: p. 8, 12
04

Reasoning

The Tribunal found that the applicants were attempting to re-agitate a dead claim that had already been adjudicated and dismissed as barred by limitation in 2019 and 2021

Source reference: p. 13-14

The court reasoned that RBE No. 30/2022 did not create a new right for the applicants; rather, it merely clarified the conditions for utilizing replacement panels during their active life

Source reference: p. 14

Since the life of the 2007 recruitment panel had long expired and multiple subsequent recruitment cycles (2010, 2012) had been completed, the applicants—who were in the 20% extra/waiting list—had no vested right to appointment

Source reference: p. 11, 14

The Tribunal emphasized that a panel's expiry is fatal to appointment claims unless a writ was filed during its currency, which was not the case here

Source reference: p. 15
05

Holding

The Tribunal dismissed the Original Application, holding that no relief could be granted because the currency of the selection panel had ended and the matter was previously settled by the High Court

The court directly answered that RBE No. 30/2022 offers no support to the applicants as it apply only to "current" panels

Source reference: p. 15

The prayer for publishing a replacement panel for the 2007 advertisement was rejected. No costs were awarded

Source reference: p. 15
CAT - ['Allahabad']

Original Court PDF

VIJAY KUMARvsNORTH EASTERN RAILWAY

CAT - ['Allahabad'] · May 15, 2026

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment