Finality of tribunal orders bars review after dismissal of special leave petition; only directly affected persons may seek review.

The Supreme Court reiterated that the Administrative Tribunal's review power under Section 22(3)(f) of the Administrative Tribunals Act, 1985 is coextensive with Order 47 Rule 1 CPC and cannot be used to reopen a final order after dismissal of the special leave petition against it. Once the original order has attained finality, judicial discipline and finality bar further review. The Court also confined the expression "person aggrieved" to those directly and immediately affected by the order, holding that a remote or speculative possibility of future promotion does not confer standing to seek review. Review petitions by such applicants were therefore unsustainable.

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Issues: (i) whether the Administrative Tribunal could review its earlier final order after the special leave petition against that order had been dismissed; (ii) whether the review applicants, though not parties to the original proceedings, were persons aggrieved entitled to maintain the review petitions.

Issue (i): whether the Administrative Tribunal could review its earlier final order after the special leave petition against that order had been dismissed.

Analysis: The power of review under Section 22(3)(f) of the Administrative Tribunals Act, 1985 is coextensive with the power of review under Order 47 Rule 1 of the Code of Civil Procedure, 1908. Once a special leave petition against the Tribunal's original order has been dismissed, that order attains finality and binding force. A review cannot then be used to reopen the matter, because doing so would undermine the finality of the judicial process and offend judicial discipline.

Conclusion: The Tribunal had no jurisdiction to entertain the review petitions after dismissal of the special leave petition.

Issue (ii): whether the review applicants, though not parties to the original proceedings, were persons aggrieved entitled to maintain the review petitions.

Analysis: The expression "person aggrieved" in the review context must be confined to persons directly and immediately affected by the order. A remote or speculative chance of future promotion does not create a legal right to seek review. The applicants were not within the zone of consideration at the relevant time, and their interest was not such as to permit reopening of an order that had already attained finality.

Conclusion: The review applicants were not persons aggrieved entitled to maintain the review petitions.

Final Conclusion: The review orders were unsustainable, and the matters requiring adjudication had to be considered afresh on their own merits by the Tribunal in accordance with law.

Ratio Decidendi: Once an order of the Tribunal has attained finality after dismissal of the special leave petition against it, the Tribunal cannot review that order at the instance of persons who are not directly and immediately affected by it, since the statutory review power is confined to the limits of Order 47 Rule 1 of the Code of Civil Procedure, 1908.

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