CAT - ['Delhi']

Review Application Dismissed as Non-Maintainable Following Implementation of Judgment and Rejection of Apex Court Review

RAILWAY vs GAUTAM BOSE

CAT - ['Delhi']JUDGMENT: April 21, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The official respondents (Review Applicants) filed a Review Application seeking reconsideraton of the judgment passed by the Central Administrative Tribunal (CAT), Principal Bench, in OA No. 4059/2023

Source reference: p. 1, 17

The original dispute involved Gautam Bose and 123 other retired railway employees ranging from Senior Section Officers to Accounts Assistants

Source reference: p. 1-17

Prior to the hearing of this RA, the matter had reached the Hon’ble Apex Court, which dismissed the Review Petition filed by the Union of India

Source reference: p. 18

Subsequently, the Railway Ministry issued an office order dated 01.04.2026 to implement the original judicial directions

Source reference: p. 18
02

Issues

1. Whether the Review Application (RA No. 97/2025) remains maintainable following the dismissal of a Review Petition by the Hon’ble Supreme Court and the subsequent implementation of the order by the department

Source reference: p. 17-18

2. Whether the delay in filing the Review Application should be condoned

Source reference: p. 18
03

Law Applied

The court applied the principle of judicial finality and the doctrine of merger, specifically regarding the maintainability of a review at a lower forum after the highest court has dismissed a review on the same subject matter

Source reference: p. 17-18

Procedural mandates of the Central Administrative Tribunal (Procedure) Rules, 1987, regarding Review Applications and Miscellaneous Applications for condonation of delay

Source reference: p. 18
04

Reasoning

The Tribunal noted that the Review Application filed by the Union of India was no longer viable because the legal controversy had attained finality at the highest level

Source reference: p. 18

The Hon’ble Apex Court had already dismissed the department's Review Petition, effectively affirming the original order

Source reference: p. 18

The Tribunal observed that the official respondents had already accepted the verdict by issuing an implementation order via the Ministry of Railways on 01.04.2026

Source reference: p. 18

Therefore, there was no "error apparent on the face of the record" or legal basis to keep the review alive

Source reference: p. 18

Regarding the procedural delay in filing, the Tribunal exercised its discretion to allow the application for condonation of delay to ensure the matter was disposed of on merits/technical finality rather than mere laches

Source reference: p. 18
05

Holding

The CAT Principal Bench held that the Review Application was not maintainable due to the dismissal of the petition by the Supreme Court and the subsequent implementation of the order by the applicants

The Tribunal formally allowed MA No. 2379/2025 for condonation of delay but dismissed RA No. 97/2025

Source reference: p. 18

All other pending Miscellaneous Applications were disposed of accordingly

Source reference: p. 18
CAT - ['Delhi']

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RAILWAYvsGAUTAM BOSE

CAT - ['Delhi'] · April 21, 2026

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