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Issues: (i) Whether an Administrative Tribunal constituted under the Administrative Tribunals Act, 1985 can entertain a public interest litigation at the instance of a stranger; (ii) Whether the Tribunal exceeded its jurisdiction in interfering with the petitioner's appointment as Lecturer in Surgical Gastroenterology.
Issue (i): Whether an Administrative Tribunal constituted under the Administrative Tribunals Act, 1985 can entertain a public interest litigation at the instance of a stranger.
Analysis: The statutory scheme confines access to the Tribunal to a "person aggrieved" and regulates applications under the Act as service-matter grievances. Read with the object of creating specialised forums for speedy redress of service disputes, the provisions do not confer plenary jurisdiction. In the light of the post-Chandra Kumar position, the Tribunal functions in a supplemental role, but its jurisdiction still remains statutory and limited to persons having a legally cognisable grievance in service matters. A total stranger cannot invoke the Tribunal's jurisdiction in the guise of public interest litigation.
Conclusion: The answer is in the negative. The Tribunal cannot entertain a public interest litigation at the instance of a total stranger.
Issue (ii): Whether the Tribunal exceeded its jurisdiction in interfering with the petitioner's appointment as Lecturer in Surgical Gastroenterology.
Analysis: The record showed that the petitioner possessed the prescribed qualification and that the competent medical authorities had treated his experience as sufficient. The Tribunal went behind the opinion of the expert authority and introduced a restrictive interpretation that the special training had to be obtained only in an institution separately recognised for imparting such training, although the rule did not so provide. Once the competent authorities had accepted eligibility, the Tribunal was not justified in undertaking its own technical assessment and substituting its view for that of the expert bodies.
Conclusion: The Tribunal exceeded its jurisdiction in restraining the petitioner's appointment.
Final Conclusion: The statutory remedy before the Tribunal is confined to service grievances of an aggrieved person, and the Tribunal cannot enlarge its jurisdiction by entertaining stranger-initiated public interest litigation or by substituting its own technical view for that of the competent expert authorities.
Ratio Decidendi: An Administrative Tribunal established under the Administrative Tribunals Act, 1985 can be approached only by a person aggrieved in a service matter, and it must not exceed its limited statutory jurisdiction by entertaining public interest litigation or by overriding the considered opinion of competent expert authorities on eligibility.