Review cannot be sustained where jurisdictional objections of necessary parties are decided on merits after hearing.

The applicants filed a Review Application (RA) seeking to set aside the Tribunal’s judgment dated 15.09.2025.

The primary grievance was that the Tribunal, in its final judgment, held that applicants no. 2 to 8 fell outside its territorial jurisdiction and granted them liberty to approach appropriate Benches.

The applicants argued that the Tribunal overlooked its own prior interlocutory order dated 11.01.2023, which had granted them permission under Rule 4(5)(a) of the CAT (Procedure) Rules, 1987, to pursue the Original Application (OA) jointly based on a common cause of action.

The respondents contended that the 2023 order was interlocutory, merged with the final judgment, and was passed before private respondents (who raised the jurisdictional objection) were impleaded.

1. Whether the failure to notice a prior interlocutory order allowing a joint application constitutes an "error apparent on the face of the record" justifying a review of the final judgment.

2. Whether an order passed under Rule 4(5)(a) regarding joint pursuit of litigation overrides the territorial jurisdiction objections raised by subsequently impleaded private respondents.

Rule 4(5)(a) of the CAT (Procedure) Rules, 1987, which permits multiple applicants to join in a single application if they share a common cause of action to prevent multifariousness.

Principles of Natural Justice, which mandate that necessary parties (private respondents) must be heard on matters of jurisdiction before a final adjudication.

A review is not a substitute for an appeal and requires an error that would have altered the conclusion.

The Tribunal admitted that the order dated 11.01.2023 was not specifically mentioned in the final judgment but concluded this omission was not fatal.

The court reasoned that at the time the joint application was allowed, only official respondents were parties; private respondents 3 to 7—who were "necessary and proper parties"—had not yet been impleaded.

Once impleaded on 29.11.2023, these private respondents were entitled to raise jurisdictional objections under the principles of natural justice.

The Tribunal found that even if the 2023 order had been considered, the legal conclusion regarding territorial jurisdiction would remain unchanged because procedural joinder of parties cannot overrule the substantive legal requirements of territorial jurisdiction when challenged by affected private parties.

The final holding affirmed the judgment dated 15.09.2025, maintaining that applicants outside the Lucknow Bench's jurisdiction must pursue their claims in the appropriate regional Benches.