The CAT lacks jurisdiction to review NCCSA recommendations absent a Section 14(2) notification.

The applicant, while serving as Director General of Health Services (Link-I), Government of NCT of Delhi, was suspended in January 2025.

After the Tribunal set aside extensions of her suspension in O.A. No. 1271/2025, she was reinstated in June 2026.

The National Capital Civil Services Authority (NCCSA), constituted under Section 45E of the Government of National Capital Territory of Delhi Act, 1991, had recommended initiation of disciplinary proceedings against her; a charge memorandum followed.

The applicant filed this O.A. seeking to quash the NCCSA’s recommendations, alleging, among other grounds, breach of natural justice and bias.

Whether the Central Administrative Tribunal had jurisdiction under Section 14(2) of the Administrative Tribunals Act, 1985, to adjudicate a challenge to recommendations made by the NCCSA, where no notification applying the Act to the NCCSA had been identified

Section 14(2) of the Administrative Tribunals Act, 1985 provides that the Central Government may, by notification, apply the relevant provisions of the Act to specified local or other authorities and bodies; the Tribunal’s jurisdiction over an authority covered by that provision depends on such notification.

The Tribunal also relied on Pearlite Liners (P) Ltd. v. Manorama Sirsi, (2004) 3 SCC 172, for the principle that a proceeding seeking relief beyond the forum’s jurisdiction should not proceed to trial on the merits.

The principal relief sought was the quashing of recommendations made by the NCCSA under Section 45H(2) of the 1991 Act. The Tribunal found no Central Government notification under Section 14(2) extending the Administrative Tribunals Act to the NCCSA.

Its statutory constitution alone did not confer jurisdiction on the Tribunal to determine the validity of the NCCSA’s recommendations. Applying Pearlite Liners, the Tribunal concluded that it should not examine the merits, including the applicant’s allegations of natural-justice violations, bias, arbitrariness, mala fides, or non-application of mind.

It dismissed it at the threshold, without examining the merits of the challenge to the NCCSA’s recommendations. No order as to costs was made, and the Registry was directed to assign an appropriate number to the O.A.