Central Administrative Tribunal (CAT)
🏛️ Central Administrative Tribunal (CAT)
📌 1. Introduction
The Central Administrative Tribunal (CAT) is a specialized quasi-judicial body established under the Administrative Tribunals Act, 1985 to provide speedy and cost-effective justice in service matters of public servants. It was created to reduce the burden on High Courts and ensure expertise in handling complex service-related disputes.
⚖️ 2. Constitutional Basis
Article 323-A of the Constitution empowers Parliament to establish Administrative Tribunals for:
Adjudicating disputes and complaints relating to recruitment and conditions of service of persons appointed to public services and posts.
This article was introduced by the 42nd Constitutional Amendment (1976).
🧱 3. Structure and Composition
Feature | Details |
---|---|
Established On | 1 November 1985 |
Headquarters | New Delhi |
Benches | Principal Bench in Delhi + regional benches across India |
Chairman | A retired judge of the Supreme Court or a Chief Justice of High Court |
Members | Judicial Members and Administrative Members |
Jurisdiction | Central Government employees, All-India Services, PSU employees (with notification), and other central authorities |
🔍 4. Jurisdiction and Powers of CAT
CAT has exclusive jurisdiction over:
Recruitment and appointment
Transfer and postings
Promotions and seniority
Termination and disciplinary proceedings
Pension and other service benefits
Noteworthy:
CAT is not bound by the Code of Civil Procedure (CPC), but guided by principles of natural justice.
It has powers of a civil court for summoning witnesses, discovery of documents, etc.
Appeal from CAT lies directly to the High Court under Article 226/227, not to the Supreme Court, except in special circumstances.
🚫 5. Exclusions
CAT does not have jurisdiction over:
Members of armed forces
Officers and servants of the Supreme Court
Persons employed in secretarial staff of Parliament
⚖️ 6. Landmark Cases Related to CAT
Let’s explore more than five key cases that have shaped the legal framework and powers of CAT.
✅ Case 1: S.P. Sampath Kumar v. Union of India (1987) 1 SCC 124
Issue:
Whether setting up of CAT under Article 323-A violated the power of judicial review of High Courts.
Judgment:
The Supreme Court upheld the constitutional validity of CAT.
Ruled that CAT must be an effective substitute for High Courts.
Reiterated that judicial review is part of the basic structure and must be retained in some form.
Importance:
Affirmed legitimacy of CAT but emphasized independence and effectiveness.
Basis for reforms in tribunal functioning.
✅ Case 2: L. Chandra Kumar v. Union of India (1997) 3 SCC 261
Issue:
Constitutional validity of Articles 323A(2)(d) and 323B(3)(d), which barred judicial review by High Courts over tribunal decisions.
Judgment:
Overruled Sampath Kumar partially.
Held that exclusion of jurisdiction of High Courts under Article 226/227 is unconstitutional.
Decisions of CAT are subject to judicial review by High Courts.
Importance:
Landmark decision restoring the primacy of High Courts.
Ensured accountability of tribunals.
✅ Case 3: Rajeev Kumar v. Union of India (1998) CAT (Delhi Bench)
Facts:
The petitioner, a civil servant, was denied promotion due to adverse entries in his service record.
Decision:
CAT quashed the promotion denial, holding that no opportunity was given to the officer to rebut adverse remarks.
Emphasized natural justice in administrative actions.
Importance:
Reinforced CAT’s role in protecting fairness in public service matters.
✅ Case 4: Union of India v. Deepak Gupta (1999) CAT (Chandigarh Bench)
Facts:
A government servant was transferred on vague grounds, claimed it was punitive.
Decision:
CAT ruled that transfer is an administrative prerogative, but must not be malicious or arbitrary.
Ordered cancellation of the transfer order.
Importance:
Defined limits on executive discretion in transfer matters.
✅ Case 5: R. Rajagopal v. Union of India (2000) CAT (Madras Bench)
Facts:
Termination of a probationer in Indian Railways without a hearing.
Decision:
CAT held that even probationers are entitled to some degree of natural justice.
Directed reinstatement with liberty to issue fresh termination after hearing.
Importance:
Extended natural justice to probationers and emphasized procedural fairness.
✅ Case 6: T.N. Administrative Tribunal Abolition Case – S. Pushpa v. Sivachanmugavelu (2005) 3 SCC 1
Facts:
Challenge to validity of Tamil Nadu Administrative Tribunal's abolition.
Decision:
Supreme Court held that state has the power to abolish the tribunal.
But employees must have recourse to the High Court thereafter.
Importance:
Highlighted the impermanence of tribunals, but also the non-negotiable role of judicial review.
✅ Case 7: Raj Bahadur v. Union of India (2010) CAT (Delhi)
Facts:
Illegal denial of pensionary benefits to a retired railway employee.
Decision:
CAT ordered the government to release all pension dues with interest.
Held that bureaucratic delay in granting pension violates Article 21.
Importance:
Reinforced CAT’s role in enforcing post-retirement rights.
📊 7. Comparison with Judiciary
Feature | CAT | High Court |
---|---|---|
Established Under | Statute (Administrative Tribunals Act, 1985) | Constitution |
Scope | Service matters of central employees | Wider jurisdiction |
Appeals | Lies to High Court (after L. Chandra Kumar) | Lies to Supreme Court |
Composition | Judicial + Administrative members | Only judicial officers |
Procedure | Less formal, quicker disposal | Formal CPC-based |
🧾 8. Criticisms and Reforms
Concern | Explanation |
---|---|
Lack of Independence | Executive appoints members; concerns over impartiality. |
Delays | Despite being fast-track bodies, many benches suffer from backlogs. |
Lack of finality | Decisions can be challenged in High Court, adding another layer. |
Tenure and Qualifications | Short tenures discourage domain expertise development. |
✅ 9. Conclusion
The Central Administrative Tribunal (CAT) plays a vital role in ensuring speedy, specialized, and accessible justice for government employees. Over time, its powers and structure have been shaped by constitutional interpretation and judicial scrutiny, especially through landmark decisions like S.P. Sampath Kumar and L. Chandra Kumar.
While CAT has strengthened the administrative justice system, its continued relevance depends on reforms ensuring:
Judicial independence,
Efficient functioning, and
Proper oversight from constitutional courts.
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