Case Details
This order pertains to O.A. No. 296/2025, M.A No. 4724/2025, M.A No. 296/2025, M.A No. 297/2025 and M.A No. 3709/2025, heard by the Central Administrative Tribunal, Principal Bench, New Delhi.
The matter was reserved on 2025-11-04 and pronounced on 2025-11-12.
The Bench comprised Hon'ble Mrs. Harvinder Kaur Oberoi, Member (J) and Hon'ble Dr. Sumeet Jerath, Member (A).
Parties Involved
Applicants:
- Niranjan Kumar (aged about 26 yrs), S/o Jamiri Lal, R/o 53 A Gali no. 2, West Sagar Pur, Southwest Delhi 110046.
- Babloo (aged about 24 yrs), S/o Dhani Mahto, R/o C 681 Metro Vihar, Holambi Kalan, North West Delhi, Delhi-110082.
- Manish Kumar (aged about 20 yrs), S/o Hariom Singh, R/o Bhaipur, Bulandshahr, Uttar Pradesh, 203141.
- Rajesh Kumar (aged about 32 yrs), S/o Sherpal Singh, R/o Bhaipur, Bulandshahr, UP, 203141.
(Advocates for Applicants: Mr. Shrikant Prasad and Mr. Aryan Kumar)
Respondents:
- Union of India, Through Secretary, Ministry of Railways, Rail Bhawan, New Delhi.
- Railway Recruitment Board, Executive Director Establishment (RRB), Railway Board, Rail Bhawan, New Delhi.
- Railway Recruitment Cell, Northern Railway, Through General Manager, Block C. Lajpat Nagar I, Lajpat Nagar, New Delhi.
- Union of India, Ministry of Skill Development & Entrepreneurship, Through, Secretary, Shram Shakti Bhawan, Rafi Marg, New Delhi.
(Advocates for Respondents: Mr. R. V. Sinha, Mr. A. S. Singh, Mr. Ashish Singh, Ms. Shriya Sharma, Ms. Jyoti Garg, Mr. Akshit Pradhan with Ms. Muskan Goyal and Mr. Vikash Chaurasia CLA, NRHQ)
Background and Applicants' Grievance
The applicants filed the O.A. under section 19 of the Administrative Tribunals Act, 1985, challenging the sudden revision in minimum educational qualifications for Level-1 posts in Railways vide Circular No. CEN 08/2024 dated 2025-01-21, issued by the Railway Recruitment Board. They contended that from 2018 to 2024, the minimum qualification was consistently 10th pass + ITI. However, the revised criteria in Annexure A reduced it to 10th Pass or ITI or equivalent or NAC, significantly widening eligibility and affecting approximately 39,20,067 candidates who had prepared based on earlier qualifications. They argued this change lacked adequate publicity and undermined transparency and legitimate expectations.
Reliefs Sought by Applicants
- To quash Annexure A of CEN 08/2024 Dated 2025-01-21.
- To direct respondents to proceed with CEN 08/2024 recruitment using earlier prescribed qualifications of 10th pass plus ITI or NAC.
- To grant any other appropriate relief.
Respondents' Arguments
The respondents argued on technical grounds and merits, stating that:
- The application is in the nature of a Public Interest Litigation (PIL) and the applicants lack locus standi to challenge eligibility criteria, which is the exclusive domain of the employer.
- The applicants challenged CEN 08/2025 dated 2025-01-21, which they claimed was non-existent. They clarified that the advertisement (No. 08/2024) was published on 2025-01-22, consistent with modified eligibility notified on 2025-01-02.
- Applicants relied on superseded policy/recruitment rules (RBE 1/2025 dated 2025-01-02).
- They alleged misrepresentation and fraud by the applicants, noting that the affidavit was not properly signed or verified, and representations to respondents were made by individuals not party to the O.A.
- They cited various judgments, including Union of India & Ors Vs Kali Das Batish and Sankarsan Das vs. UOI, to support that candidates have no legitimate expectation for appointment, only the right to compete.
- The decision to change qualifications was an