Review cannot add interest to a pay-fixation order absent an apparent error.

The applicant sought review of the Tribunal’s order dated 24 June 2025, which directed the respondents to grant him the benefit of pay fixation in the scale of Rs. 5,500–9,000 with effect from 13 February 2001, but denied interest.

The original application, instituted in 2013, had also been allowed without interest; after the respondents challenged that order, the Madhya Pradesh High Court remitted the matter to the Tribunal, which later passed the order sought to be reviewed.

The applicant sought interest at 18% per annum from 13 February 2001 until realization, arguing that its exclusion was mechanical.

1. Whether the order’s refusal to award interest disclosed an error apparent on the face of the record or another ground warranting review.

2. Whether the Tribunal could use review jurisdiction to add the requested interest relief absent a legally recognised ground for review.

Under Section 22(3)(f) of the Administrative Tribunals Act, 1985, the Tribunal’s review power is analogous to a civil court’s power under Section 114 read with Order 47 Rule 1 of the Code of Civil Procedure.

Review is confined to the grounds recognised by Order 47 Rule 1; it is not an appeal or a fresh hearing to obtain a different or additional relief.

An error apparent must be self-evident and not require a long process of reasoning.

The Tribunal relied on Jain Studios Ltd. v. Shin Satellite Public Co. Ltd., (2006) 5 SCC 501; Ajit Kumar Rath v. State of Orissa, (1999) 9 SCC 596; Meera Bhanja v. Nirmala Kumari Choudhury, (1995) 1 SCC 170; Union of India v. Tarit Ranjan Das, 2004 SCC (L&S) 160; and State of West Bengal v. Kamal Sengupta, (2008) 2 SCC (L&S) 735.

The Tribunal found that the applicant’s request sought an additional monetary relief—interest—which had not been granted in the final order.

The assertion that the omission was mechanical did not establish a patent error, and retrospective pay fixation did not, by itself, entitle the applicant to interest for the entire period.

Granting interest through review, without demonstrating an apparent error or another recognised ground, would impermissibly reopen the concluded proceedings and exceed the limited review jurisdiction.

It dismissed the review application insofar as it sought to modify the final order to include interest; there was no order as to costs.