Review jurisdiction is limited to self-evident errors and cannot be exercised to correct erroneous decisions.

The Review Applicant, a Scientist-B at the Central Ground Water Board, was eligible for promotion to Scientist-C (and subsequently Scientist-D) under the Flexible Complementing Scheme (FCS) from 2009 onwards.

On May 2, 2018, the UPSC received a proposal for the Board of Assessment to consider promotions for the years 2009–2013.

However, by the time the Board met on November 5, 2018, the applicant had been arrested (October 11, 2017) following a CBI FIR and placed under suspension.

Consequently, the respondents kept his promotion result in a "sealed cover" per Department of Personnel and Training (DoP&T) guidelines.

The Tribunal, via an order dated January 30, 2026, dismissed the applicant's Original Application (O.A.), upholding the sealed cover procedure and rejecting his claim for Scientist-D promotion.

The applicant filed this Review Application (R.A.) asserting that the Tribunal ignored Para 5 of the DoP&T OM dated September 14, 1992, and failed to note that no proceedings existed on his initial eligibility date of January 1, 2009.

1. Whether there exists an "error apparent on the face of the record" in the order dated January 30, 2026, to justify a review under Section 22(3)(f) of the Administrative Tribunals Act, 1985.

2. Whether the non-consideration of specific paragraphs of a circular or re-appreciation of facts already on record constitutes sufficient grounds for review.

The Tribunal applied Section 22(3)(f) of the Administrative Tribunals Act, 1985, and Rule 17 of the CAT (Procedure) Rules, 1987, which align the Tribunal's review powers with Section 114 and Order 47 Rule 1 of the CPC.

It strictly followed the principles laid down by the Supreme Court in State of West Bengal v. Kamal Sengupta (2008), which establish that a review is only permissible for self-evident errors, not those requiring a long process of reasoning, and that an erroneous order cannot be corrected under the guise of a review.

The Tribunal observed that the original order was passed after a comprehensive hearing of both parties and a thorough perusal of the pleadings.

It reasoned that the applicant’s contentions—specifically regarding the applicability of Para 5 of the DoP&T OM and the lack of pending proceedings in 2009—did not constitute "new grounds" but were attempts to re-argue the merits of the case.

Referring to the Kamal Sengupta precedent, the Tribunal noted that if an error is not self-evident and requires a "long process of reasoning" to discover, it cannot be deemed an "error apparent on the face of record".

The Court found that the applicant failed to demonstrate any clerical or patent error that met the high threshold required by Order 47 Rule 1 of the CPC.

It concluded that the application was misconceived as no error apparent on the face of the record was established.

The original findings regarding the validity of the "sealed cover" procedure and the rejection of the promotion to Scientist-D remain undisturbed.