Reserve Trained Pool service benefits apply in rem to all similarly situated employees.

The Review Applicants (Union of India/Department of Posts) sought a review of a common judgment dated 23.07.2025, which had directed them to extend benefits (MACP, pensionary benefits, etc.) to the original applicants based on service rendered in the "Reserve Trained Pool" (RTP) between 1983 and 1985

The original judgment relied on a Delhi High Court decision in Union of India & Ors. v. Raksh Pal Singh & Ors.

The Review Applicants filed these applications with a three-day delay, seeking recall on the grounds that certain judgments cited by them were not considered by the Tribunal in the impugned order

It was noted that a similar review application in a lead matter (O.A. No. 4477/2024) had already been dismissed on 17.11.2025

1. Whether the three-day delay in filing the Review Applications should be condoned?

2. Whether there is an error apparent on the face of the record justifying a review of the judgment dated 23.07.2025, given the binding nature of the High Court's in rem directions?

The Tribunal applied the principle of in rem applicability of judicial precedents as affirmed by the Hon’ble High Court of Delhi in Union of India & Ors. v. Raksh Pal Singh & Ors. (W.P.(C) 7301/2025)

This principle mandates that when a court decides a question of law regarding service benefits for a class of employees, the benefits must be extended to all similarly situated persons to avoid unnecessary litigation

Furthermore, the Tribunal exercised its power to dismiss review petitions that constitute an "utter misuse of the process of law" when the core legal issue has already been settled by superior courts and prior review attempts in connected matters have failed

The Tribunal first condoned the marginal delay of three days in filing the Review Applications (R.A.s) as the original applicants raised no objection

Regarding the merits of the review, the Tribunal observed that the Review Applicants failed to demonstrate any error in the application of the law.

The Tribunal emphasized that the Delhi High Court in Raksh Pal Singh (2025) had specifically upheld the counting of "Reserve Trained Pool" service for financial benefits and explicitly ordered that this benefit apply in rem

Since the Review Applicants did not dispute that the original applicants were similarly situated, their attempt to re-litigate the issue was deemed a misuse of the legal process

The Tribunal further noted that the dismissal of a similar R.A. in the lead case (O.A. No. 4477/2024) rendered the present R.A.s redundant and vexatious

The Court held that the Review Applicants were bound by the in rem directions of the High Court and that filing repetitive reviews in connected matters was an abuse of process

Consequently, the Tribunal imposed a cost of Rs. 25,000 in each R.A. (Totaling Rs. 50,000) on the Review Applicants, payable to the "Poor Patients Funds under the Aegis of AIIMS"