Statutory administrative remedies must be exhausted before approaching the Administrative Tribunal for judicial relief.

The Applicant, a Principal Scientist at CSIR-Indian Institute of Chemical Biology (IICB), was issued a warning letter on July 8, 2025, alleging misconduct and breach of conduct rules for participating in an agitation by contractual staff

The Applicant denied these allegations on July 15, 2025; however, adverse entries were recorded against him on July 18, 2025, which the Applicant claims were made without providing him an opportunity for defense

A representation against these comments was rejected on December 2, 2025

The Applicant approached the Tribunal under Section 19 of the Administrative Tribunals Act, 1985, seeking to quash the warning and adverse entries

The Respondents raised a preliminary objection, stating the Applicant had not exhausted the internal administrative remedy of appealing to the Director General of CSIR (DGCSIR)

1. Whether the Applicant had exhausted the alternative administrative remedies available under the service rules before approaching the Tribunal

2. Whether the matter should be remitted to the Director General of CSIR (DGCSIR) for statutory consideration

Section 19 of the Administrative Tribunals Act, 1985, which stipulates the procedure for filing applications and implies the exhaustion of alternative remedies

Rules Regulations and Bye-Laws of the Memorandum of Association of CSIR, which provide for a right of appeal/representation to the Director General of CSIR (DGCSIR) against decisions of the Management Council or regarding organizational disputes

The Tribunal analyzed the procedural posture of the case in light of the Respondents' submission that an internal remedy via the DGCSIR was still available to the Applicant

The Respondents produced the CSIR Bye-Laws, which establish the DGCSIR as the authority for resolving disputes arising from management decisions

Despite the Applicant’s objection to remitting the matter, the Tribunal determined that judicial economy and administrative protocol necessitated the exhaustion of this internal channel

The Tribunal reasoned that a directed, time-bound consideration by the DGCSIR would provide the Applicant with a formal administrative review of the alleged misconduct and the subsequent adverse entries

It held that the Applicant is at liberty to file a comprehensive representation to the DGCSIR within 15 days of the order

The DGCSIR is directed to consider and dispose of the representation via a reasoned and speaking order within 45 days of receipt

No order as to costs was made