Natural Justice | Arbitrary Cancellation of Departmental Selection Post-Written Exam Violates Service Rules : CAT Cuttack

The Central Administrative Tribunal, Cuttack Bench has reaffirmed that departmental selections cannot be cancelled arbitrarily after completion of written examinations. The judgment underscores the binding nature of Railway Board directives and the limits of administrative discretion in service matters, providing crucial relief to employees whose promotional processes were unlawfully disrupted.

Background & Facts

The Dispute

Five Loco Pilots (Goods/Passenger) working under the Chief Controller of Stores, Sambalpur Division of East Coast Railway filed an Original Application challenging the cancellation of their departmental selection process for promotion to the post of Chief Loco Inspector (CLI). The selection process, initiated by Notification dated 10.01.2024, was cancelled vide letter dated 17.10.2025 despite completion of written examinations and publication of results.

Key Facts

• 10.01.2024: Notification issued for filling 11 CLI posts (UR-8, SC-2, ST-1) in Level-7 (GP Rs. 4600)
• 14.09.2024, 18.09.2024, 21.09.2024: Written examinations conducted
• 16.10.2024: Result of written test published
• 05.03.2025: Railway Board issued letter cancelling all pending selections not finalized by 04.03.2025
• 28.03.2025: Railway Board partially rescinded cancellation for selections where exams were held before 04.03.2025
• 22.05.2025: Applicants submitted representations to complete the selection process
• 17.10.2025: Principal Chief Personnel Officer cancelled the selection citing 'administrative reasons'
• 24.10.2025: Divisional Railway Manager directed fresh selection as per RBE No. 47/2025 (CBT Mode)

Procedural History

• 2025: Original Application (OA No. 260/00355) filed before CAT Cuttack
• 10.10.2025: CAT directed respondents to take decision on Railway Board's 28.03.2025 letter
• 19.05.2026: Final arguments heard
• 22.05.2026: Judgment pronounced

The Parties' Positions

Applicants' Contentions:

• The selection process was arbitrarily cancelled despite completion of written exams and publication of results
• Railway Board's 28.03.2025 letter mandated finalization of selections where exams were held before 04.03.2025
• No specific irregularities were cited for cancellation
• Cited Aniruddha Purohit & Ors Vs UOI & Ors (W.P(C) No. 15193/2025) where Orissa High Court directed completion of similar selection process

Respondents' Contentions:

• Railway Board's 05.03.2025 letter empowered cancellation of pending selections
• Notification dated 10.01.2024 reserved right to cancel/modify selection process
• Alleged irregularities in selection process necessitated cancellation
• Fresh selection to be conducted as per RBE No. 47/2025 (CBT Mode)

Relief Sought

The applicants sought:

1. Quashing of letters dated 17.10.2025 and 24.10.2025
2. Direction to complete the ongoing selection process as per Railway Board's 28.03.2025 letter
3. Preparation of final merit panel from qualified candidates of written result dated 16.10.2024
4. Promotion of applicants to the post of CLI

The Legal Issue

The central question was whether the Railway Administration could lawfully cancel a departmental selection process after conducting written examinations and publishing results, in contravention of Railway Board's directive to finalize such selections.

Arguments Presented

For the Applicants

• Relied on principles of natural justice and rule of law to argue that cancellation was arbitrary
• Cited Railway Board's letter dated 28.03.2025 which mandated finalization of selections where exams were held before 04.03.2025
• Argued that no specific irregularities were cited for cancellation
• Referenced Mohinder Singh Gill & Anr Vs The Chief Election Commissioner (1978 AIR 851) on objective interpretation of public orders
• Cited Som Raj & Ors v State of Haryana & Ors (AIR 1990 SC 1176) on limits of administrative discretion

For the Respondents

• Contended that Railway Board's 05.03.2025 letter empowered cancellation of pending selections
• Argued that Notification dated 10.01.2024 reserved right to cancel/modify selection process
• Stated that alleged irregularities in selection process necessitated cancellation
• Emphasized that fresh selection would be conducted as per RBE No. 47/2025 (CBT Mode)

The Court's Analysis

The Tribunal conducted a detailed examination of the Railway Board's directives and the principles governing administrative action:

1. Binding Nature of Railway Board Directives: The Tribunal extracted and analyzed the full text of Railway Board letters dated 05.03.2025 and 28.03.2025. The 28.03.2025 letter explicitly stated:

   "all ongoing selections (list enclosed) where written examination were held on or before 04.03.2025 shall be finalized. The list of above selections to be finalized will be finally approved with the personal signature of PCPOS/HR Heads of Zonal Railways/PUs."

   The Tribunal noted that the written examinations were conducted on 14.09.2024, 18.09.2024, and 21.09.2024, and results were published on 16.10.2024 - all well before the cut-off date of 04.03.2025.

2. Principles of Natural Justice and Rule of Law: The Tribunal relied on Mohinder Singh Gill & Anr Vs The Chief Election Commissioner (1978 AIR 851) to emphasize that public orders must be construed objectively based on their language, not subsequent explanations. It held:

   "Public orders, publicly made, in exercise of a statutory authority cannot be construed in the light of explanations subsequently given by the officer making the order of what he meant, or of what was in its mind, or what he intended to, do."

   The Tribunal found that the cancellation letter dated 17.10.2025 cited only 'administrative reasons' without specifying any irregularities, making the action arbitrary.

3. Limits of Administrative Discretion: The Tribunal cited Som Raj & Ors v State of Haryana & Ors (AIR 1990 SC 1176) to underscore that administrative discretion must be exercised within clearly defined limits:

   "In a system governed by Rule of Law, discretion when conferred upon an executive authority must be confined within clearly defined limits. If the discretion is exercised without any principle or without any rule, it is a situation amounting to the anti-thesis of Rule of Law."

   It held that the authority concerned had no unfettered power to deviate from the Railway Board's directive.

4. Judicial Precedents on Arbitrary Action: The Tribunal relied on several Supreme Court judgments:

   • Dhananjaya Reddy Vs. State of Karnataka (2001) 4 SCC 9: "Where law requires a thing to be done in a certain manner, it must be done in that way or not at all."
   • Ram Chandra Keshav Adke Vs. Govind Joti Chavare (AIR 1975 SC 915)
   • State of UP Vs. Singhara Singh (AIR 1964 SC 358)

   It also cited the Orissa High Court's decision in Aniruddha Purohit & Ors Vs UOI & Ors (W.P(C) No. 15193/2025), which held that a constitutional employer cannot act arbitrarily and must conduct itself with fairness.

5. Conclusion on Arbitrariness: The Tribunal concluded that the cancellation of selection was unlawful as it:

   • Contradicted the Railway Board's explicit directive
   • Lacked specific reasons or irregularities
   • Was not preceded by any clarification from the Railway Board
   • Directed fresh selection without legal basis

The Verdict

The Tribunal allowed the Original Application and:

1. Quashed the cancellation decision communicated in letter dated 17.10.2025
2. Quashed any further actions taken pursuant to the said letter
3. Remitted the matter back to the respondents with the following directions:
   • To seek further clarification from the Railway Board if necessary
   • To complete the selection process pursuant to the result of the written test published on 16.10.2024
   • To accomplish the above within 16 weeks from the date of receipt of the order
4. Warned that delay would be viewed seriously in any subsequent legal proceedings
5. Disposed of all pending Miscellaneous Applications
6. Awarded costs, though reluctantly

What This Means For Similar Cases

Administrative Discretion Has Clear Limits

• Railway Board Directives Are Binding: Subordinate authorities cannot deviate from Railway Board directives without seeking clarification. The Tribunal emphasized that the 28.03.2025 letter explicitly mandated finalization of selections where exams were held before 04.03.2025.
• Arbitrary Cancellation Is Unlawful: Cancelling selections without citing specific irregularities or reasons violates principles of natural justice and rule of law. The Tribunal held that 'administrative reasons' alone are insufficient justification.

Selection Processes Must Be Completed Transparently

• No Mid-Stream Changes: Once a selection process is initiated, it cannot be changed or cancelled arbitrarily. The Tribunal noted that the respondents attempted to conduct fresh selections under RBE No. 47/2025, which was impermissible.
• Judicial Scrutiny of Administrative Actions: Courts will intervene when administrative actions are arbitrary, unreasonable, or contrary to established directives. The Tribunal relied on Supreme Court judgments to underscore this principle.

Practical Takeaways for Practitioners

• Document Compliance with Directives: Ensure that all administrative actions comply with higher authority directives. In this case, the Railway Board's 28.03.2025 letter was the key document.
• Seek Clarification Before Acting: If there is ambiguity in directives, authorities must seek clarification rather than acting unilaterally. The Tribunal criticized the respondents for not seeking clarification from the Railway Board.
• Timelines Matter: The Tribunal set a strict deadline of 16 weeks for compliance, warning of serious consequences for delay. Practitioners should emphasize timelines in similar cases.
• Cite Precedents on Arbitrariness: Use judgments like Som Raj, Dhananjaya Reddy, and Mohinder Singh Gill to argue against arbitrary administrative actions.