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Legal Case Shots

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Service & Administrative LawSupreme Court of India

Central Council for Research in Ayurvedic Sciences vs Bikartan Das

Civil Appeal · 2023 INSC 733Decided 16 Aug 2023
Civil Appeal No. 3339 of 2023
Dr. Dhananjaya Y. Chandrachud · J.B. Pardiwala · M.M. Sundresh

Background

Dr. Bikartan Das was a Research Assistant with the Central Council for Research in Ayurvedic Sciences (CCRAS), an autonomous body under the Ministry of AYUSH. In 2017, the government raised the retirement age to 65 for AYUSH doctors working directly under the Ministry and in CGHS hospitals, but the Ministry clarified this enhancement did not extend to employees of autonomous bodies like CCRAS. Dr. Das, nearing the earlier retirement age of 60, claimed he should also get the benefit of retiring at 65 since he sometimes treated patients. The Central Administrative Tribunal (CAT) rejected his claim after examining CCRAS's own bye-laws, but the Orissa High Court, on a writ petition, overturned the CAT's decision and ruled in his favour.

Decision Breakdown

The Supreme Court held that the High Court had exceeded the limited scope of its supervisory "certiorari" jurisdiction over tribunal decisions. Reviewing a long line of precedent, the Court explained that a writ court cannot act as an appellate court re-weighing facts or substituting its own view merely because it disagrees with a tribunal's reasonable interpretation of rules: interference is permitted only for genuine jurisdictional errors, violations of natural justice, or manifest errors on the face of the record. Since the CAT had carefully analysed CCRAS's bye-laws and government orders and reached a plausible conclusion that the retirement-age enhancement did not apply to CCRAS employees, the High Court was wrong to reverse it. The Supreme Court therefore set aside the High Court's judgment and restored the CAT's order rejecting Dr. Das's claim.

Lesson Learnt

When a specialised tribunal has fairly considered the facts and rules and reached a reasonable conclusion, a High Court exercising writ jurisdiction cannot simply substitute its own preferred outcome: judicial review of tribunal decisions is meant to check jurisdictional and procedural errors, not to re-decide the case on merits.

Central Council for Research in Ayurvedic Sciences vs Bikartan Das – Legal Case Shots | LegalAware