CAT - ['Delhi']

Tribunal Lacks Jurisdiction to Adjudicate Claims Involving Contractual Employees Engaged via Private Entities

MANZOOR ALI vs STEEL AUTHORITY OF INDIA LIMITED (SAIL)

CAT - ['Delhi']JUDGMENT: April 29, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

Eighteen applicants, led by Manzoor Ali, filed an Original Application (OA) before the Central Administrative Tribunal (CAT) seeking regularization of their services and equal pay for equal work

Source reference: p. 1-3, 5

The applicants were engaged as security guards and housekeeping staff

Source reference: para. 2

While they claimed to work under the direct control and supervision of Respondent No. 1 (Steel Authority of India Ltd.), they were officially engaged as contract laborers through Respondent No. 2 (M/s Rakshak Securitas Private Limited)

Source reference: para. 2
02

Issues

Whether the Central Administrative Tribunal has the jurisdiction to entertain an Original Application involving contract labor engaged by a private security entity

Source reference: para. 3
03

Law Applied

The rule dictates that the Tribunal's jurisdiction is confined to matters involving "service matters" of persons appointed to public services and posts in connection with the affairs of the Union or notified authorities; it does not extend to private entities or contractual arrangements where the employer (in this case, a private security firm) does not fall within the Tribunal's ambit

Source reference: para. 3

Administrative Tribunals Act, 1985

Source reference: para. 3
04

Reasoning

The Bench analyzed the employment structure of the applicants to determine its jurisdictional competence. It noted that the applicants were formally engaged as contract labor through Respondent No. 2, M/s Rakshak Securitas Private Limited

Source reference: para. 3

The Chairman observed that because Respondent No. 2 is a private entity (a "Private Limited" company) located in Dwarka, New Delhi, it does not fall under the statutory jurisdiction of the Tribunal

Source reference: para. 3

Consequently, even though the applicants sought relief against a public sector undertaking (SAIL), the nature of their engagement through an excluded private respondent precluded the Tribunal from adjudicating the dispute

Source reference: para. 3
05

Holding

The Tribunal held that it lacks the jurisdiction to entertain the present OA due to the private nature of the contracting employer (Respondent No. 2)

The OA was dismissed with no order as to costs

Source reference: para. 4

The court clarified that the applicants' remedy lies before an appropriate alternative forum in accordance with the law

Source reference: para. 3
CAT - ['Delhi']

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MANZOOR ALIvsSTEEL AUTHORITY OF INDIA LIMITED (SAIL)

CAT - ['Delhi'] · April 29, 2026

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