Review jurisdiction is limited to errors apparent on record and precludes re-appreciation of evidence.

The Review Applicants, serving in various capacities (Assistant Director and Senior Scientific Officer) at the Forensic Science Laboratory (FSL) and Regional Forensic Science Laboratory (RFSL) in Delhi, sought a review of the Tribunal's order dated 20.11.2025

The Review Application (RA) was filed with a delay of 71 days beyond the statutory 30-day limitation period

Consequently, the applicants filed Miscellaneous Application (MA) No. 1435/2026 seeking condonation of the said delay

1. Whether the applicants demonstrated "sufficient cause" or a "cogent explanation" to justify the condonation of a 71-day delay in filing the Review Application

2. Whether the Review Application established an "error apparent on the face of the record" sufficient to invoke the Tribunal's limited review jurisdiction

The Tribunal applied Section 22(3)(f) of the Administrative Tribunals Act, 1985, read with Rule 17 of the Central Administrative Tribunal (Procedure) Rules, 1987, which governs the power and procedure for review

Regarding condonation of delay, the court relied on Collector, Land Acquisition, Anantnag & Anr. v. Mst. Katiji & Ors. (1987), establishing that while a liberal approach is preferred, "sufficient cause" must be shown

Postmaster General & Ors. v. Living Media India Ltd. & Anr. (2012), which prohibits condoning delay on purely sympathetic grounds in the absence of a plausible explanation

For the merits of the review, the Tribunal followed State of West Bengal & Ors. v. Kamal Sengupta & Anr. (2008) and Ajit Kumar Rath v. State of Orissa & Ors. (1999), both of which hold that review jurisdiction is limited to correcting patent errors and cannot be used for re-appreciation of evidence or as a substitute for a fresh hearing

The Tribunal first addressed the MA for condonation of delay, finding that the applicants offered no sufficient or cogent explanation for the 71-day lapse, noting that limitation cannot be waived in a routine or mechanical manner

Moving to the merits of the RA, the Tribunal observed that the applicants’ submissions were merely a repetition of arguments already considered during the original adjudication of OA No. 3359/2024

The court reasoned that the RA was an attempt to seek a re-hearing of the entire matter, which is impermissible under the narrow scope of review jurisdiction

Since no new material was brought forward and no patent error in the order dated 20.11.2025 was demonstrated, the Tribunal found no grounds for interference

Consequently, the Review Application was dismissed on the dual grounds of being barred by limitation and lacking merit, as it failed to satisfy the criteria for "error apparent on the face of the record"