High Court dismisses writ petition challenging service matter decision, holding that disputes relating to Steel Authority of India Ltd. employees fall within the exclusive jurisdiction of the Central Administrative Tribunal per 2010 government notification. The judgment upholds existing precedent and directs litigants to appropriate alternate remedy, reaffirming the binding authority of such notifications for future employment and service law litigation concerning SAIL.
Summary
| Category | Data |
|---|---|
| Case Name | WPC/1308/2012 of S.N.PANDE Vs UNION OF INDIA and ORS |
| CNR | CGHC010068472012 |
| Date of Registration | 16-07-2012 |
| Decision Date | 02-09-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | HON’BLE SHRI JUSTICE RAKESH MOHAN PANDEY |
| Court | High Court Of Chhattisgarh |
| Precedent Value | Binding on lower courts within Chhattisgarh; reaffirms settled law regarding CAT jurisdiction over SAIL service matters |
| Overrules / Affirms | Affirms the jurisdiction of the Central Administrative Tribunal as notified by the Government of India |
| Type of Law | Service Law / Administrative Law |
| Questions of Law | Whether the High Court possesses jurisdiction to entertain writ petitions concerning service matters of SAIL employees after the 2010 notification? |
| Ratio Decidendi |
The Court held that since the Government of India Notification dated 31.03.2010 notifies that service matters relating to SAIL are within the jurisdiction of the Central Administrative Tribunal, the petitioner is constrained to approach the Tribunal. The High Court declined to exercise jurisdiction in light of the availability of this alternative remedy. The writ petition was dismissed for want of jurisdiction, with liberty to the petitioner to avail remedies as per law. |
| Facts as Summarised by the Court |
The petitioner challenged a notification dated 31.03.2010, which placed SAIL service matters before the CAT, and the punishment order of 14.05.2012 imposing reduction in pay scale. The petitioner’s whereabouts were untraceable despite repeated SPCs; no one appeared for the petitioner at hearing. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts and authorities within Chhattisgarh with regard to SAIL service matters per 2010 notification. |
| Persuasive For | Other High Courts considering similar service matter jurisdictional objections involving PSUs covered by Central Government notifications. |
| Follows | Follows the statutory scheme vesting CAT with jurisdiction over notified service matters (2010 Government of India Notification). |
What’s New / What Lawyers Should Note
- Reaffirms that after the 2010 Government notification, service matters pertaining to SAIL employees must be pursued before the Central Administrative Tribunal, not the High Court.
- Dismissal of writ petitions in such matters is not on merits, but for want of jurisdiction; petitioners retain liberty to approach the correct forum.
- The existence of alternative statutory remedies before the CAT precludes the High Court from adjudicating such disputes.
- Lawyers must verify relevant government notifications regarding tribunal jurisdiction before filing service-related writ petitions.
Summary of Legal Reasoning
- The High Court observed that the Union of India’s Notification dated 31.03.2010 expressly brought SAIL service matters within the jurisdiction of the Central Administrative Tribunal under Section 14 of the Administrative Tribunals Act.
- Since the petitioner’s grievance pertained to service conditions and challenge to a disciplinary penalty, the Tribunal, and not the High Court, was the correct forum.
- The petitioner’s absence and the office report noting he no longer resided at the given address further influenced the procedural disposition.
- The Court followed the settled statutory scheme and declined to keep the matter pending, expressly dismissing it for want of jurisdiction while allowing the petitioner liberty to approach the Tribunal.
Arguments by the Parties
Petitioner
None appeared for the petitioner; content of petition: challenge to the 31.03.2010 notification and the 14.05.2012 punishment order.
Factual Background
The petitioner, a Steel Authority of India Limited (SAIL) employee, challenged a Ministry of Personnel Notification dated 31.03.2010, which directed that SAIL service matters be addressed by the Central Administrative Tribunal, and a disciplinary order dated 14.05.2012 lowering his pay. Despite repeated Special Process Calls, the petitioner did not appear in court and was reported not to be residing at the address provided.
Statutory Analysis
- The Court considered the effect of the Notification dated 31.03.2010 issued by the Ministry of Personnel, Public Grievances & Pensions (Department of Personnel and Training), which invoked Section 14 of the Administrative Tribunals Act to funnel SAIL service matters to the CAT.
- The effect was to exclude High Court jurisdiction in first instance for such matters, as Tribunal jurisdiction becomes exclusive upon notification.
Procedural Innovations
- The Court, noting procedural defaults (petitioner’s repeated non-appearance, change of address), undertook summary dismissal but clarified that remedies remain available before the correct forum. Emphasizes procedural route—preliminary jurisdictional bar—over merits adjudication in similar circumstances.
Alert Indicators
- ✔ Precedent Followed – The judgment affirms and applies statutory exclusion of High Court jurisdiction upon valid notification under the Administrative Tribunals Act.
Citations
- Judgment available under citation: 2025:CGHC:44862
- NAFR (Not for Report)