Retired PFRDA Chief General Manager’s Review Plea Dismissed As CAT Finds No Apparent Error, Only A Challenge To The Merits

The Original Applicant filed a review application under Rule 17 of the Central Administrative Tribunal (Procedure) Rules, 1987, seeking review of the Tribunal’s judgment dated 20 March 2026, which had dismissed his original application.

The Tribunal considered the review application and the earlier order and found that the applicant was challenging the conclusions reached on the merits rather than identifying an apparent error or another recognised ground for review.

Rule 17 of the Central Administrative Tribunal (Procedure) Rules, 1987, read with Section 114 and Order XLVII Rule 1 of the Code of Civil Procedure, limits review to grounds such as discovery of new and important matter or evidence despite due diligence, an error apparent on the face of the record, or an analogous sufficient reason; review is not an appeal or a fresh hearing on the merits.

The Tribunal relied on Aribam Tuleshwar Sharma v. Aribam Pishak Sharma, AIR 1979 SC 1047, for the limits of review; Ajit Kumar Rath v. State of Orissa, (1999) 9 SCC 596, for the restriction against rehearing or correcting an allegedly erroneous view; and S. Madhusudhan Reddy v. N. Narayana Reddy, 2022 LiveLaw (SC) 685, for the rule that review does not permit reappreciation of evidence or repetition of arguments.

The Tribunal found that the Review Applicant’s submissions questioned the conclusions in the original judgment and would require the Tribunal to reconsider the merits.

Applying the restricted scope of review, it held that the applicant had not identified an apparent error, qualifying new evidence, or another sufficient ground of the kind recognised by the governing principles. Reconsidering the merits would therefore convert review into an impermissible appellate proceeding.

It dismissed the application in circulation.