Retirement of reporting officers or reluctance to resubmit self-appraisals constitutes no ground for judicial review.

The applicant filed a Review Application (RA) seeking to modify the Tribunal's order dated 13.12.2024

In the original Original Application (OA), the Tribunal had directed the applicant to submit filled-up self-appraisal forms for the years 2017-18, 2020-21, and 2021-22 to the respondents to facilitate the completion of his Annual Performance Assessment Reports (APARs) and the subsequent convening of a Review DPC for promotion to the post of CMO (SAG)

The applicant sought a review of this order, requesting that the 2017-18 APAR be treated as a "No Report Certificate" (NRC) and that the 2020-21 APAR be called directly from the reporting officer

The applicant argued that he had already submitted these appraisals previously and that the retirement of the reporting officer, coupled with alleged bias from the reviewing officer, should exempt him from resubmitting the forms

1. Whether there exists an error apparent on the face of the record in the order dated 13.12.2024 that warrants a review

2. Whether the retirement of a reporting officer or prior submission of self-appraisal forms constitutes a valid legal ground to review and modify a judicial direction to complete APARs

The Tribunal’s review jurisdiction is confined to correcting errors apparent on the face of the record

DoPT instructions dated 20.05.1972 and 04.07.2011, which govern the issuance of No Report Certificates (NRC) when APARs cannot be written

the administrative principle that the retirement of a reporting official does not act as a legal bar to the recording of APARs, and that compliance with court-ordered administrative procedures regarding self-appraisal is mandatory for the completion of service records

The Tribunal observed that the original order was passed in the presence of the applicant’s counsel without any objection, rendering the current grounds for review an "afterthought"

The court reasoned that the applicant failed to point out any specific error of fact or law on the face of the record

It held that even if the applicant had previously submitted self-appraisals, a subsequent judicial direction to resubmit them to facilitate an administrative conclusion (the Review DPC) must be complied with

The Tribunal further clarified that the retirement of reporting officers does not preclude the administration from finalizing APARs

The court concluded that the applicant's reluctance to comply with the established procedure for completing his service record did not constitute a valid ground for review under the limited scope of review jurisdiction

The court maintained its original directions from the order dated 13.12.2024, requiring the applicant to submit his self-appraisals to enable the completion of his APARs and the convening of the Review DPC for promotion

No order was made as to costs