Review jurisdiction cannot be invoked to reappreciate evidence or introduce subsequent material for rehearing.

Subodh Kumar Singh, a candidate for posts in the Railways carrying Pay Band ₹5,200–20,200 with Grade Pay ₹1,800, had succeeded in O.A. No. 61/2025.

By order dated 4 December 2025, the Tribunal quashed the impugned orders and directed the Railway authorities to issue him an offer of appointment in accordance with merit, subject to fulfilment of the remaining eligibility conditions.

The Union of India and the concerned Railway authorities filed a Review Application, accompanied by an application for condonation of delay.

They relied on allegedly traced additional material, including a statistical analysis/report and material concerning the use of unfair means in the examination, asserting that it established the respondent’s involvement in unfair means.

The Tribunal condoned the delay of 186 days in filing the Review Application.

Whether the alleged subsequently traced statistical analysis/report and other material relating to unfair means justified review of the Tribunal’s order dated 4 December 2025?

Whether the Review Applicants had demonstrated an error apparent on the face of the record warranting exercise of review jurisdiction?

Whether the review proceedings could be used to re-appreciate evidence and undertake a fresh adjudication of the allegations against the respondent?

The Tribunal applied the settled principle that review jurisdiction is limited and cannot be exercised as an appellate jurisdiction or as a means of rehearing a matter on merits.

A review lies only where a permissible ground, including an error apparent on the face of the record, is established; it cannot be invoked merely to secure re-appreciation of evidence.

The Tribunal also applied the principle of procedural fairness that material relied upon against a person must be supplied to enable an effective opportunity to meet the allegations; non-supply of the statistical analysis/report was treated as a specific deficiency in the original proceedings.

No specific statutory provision or judicial precedent was cited in the order.

The Tribunal found that the Review Applicants’ reliance on additional material concerning alleged unfair means effectively sought reconsideration of the evidentiary merits of the case.

Such re-appreciation would exceed the permissible scope of review and amount to an appellate or fresh adjudicatory exercise.

The original order had proceeded on the established procedural deficiency that the statistical analysis/report relied upon against the respondent had not been supplied to him, thereby denying him an effective opportunity to answer the allegations.

The subsequent attempt to introduce further material could not cure that deficiency within review proceedings or convert the review into a new determination of whether the respondent had used unfair means.

Since no error apparent on the face of the record was demonstrated, the requirements for review were not satisfied.

It held that the alleged additional evidence did not disclose any error apparent on the face of the record and that the Review Applicants were impermissibly seeking a rehearing on merits.

The Review Application was accordingly dismissed, while the original direction to issue an offer of appointment remained undisturbed.

Pending miscellaneous applications, if any, were disposed of, with no order as to costs.