Limitation under the Administrative Tribunals Act barred belated challenge to punishment order and excluded merits review.

Section 21(1)(a) of the Administrative Tribunals Act requires an application to be filed within one year from the final order, and delay can be excused only on sufficient cause under Section 21(3). In the stated facts, the punishment order was communicated in 2007 but the application was filed in 2015, with no explanation justifying condonation. The argument that pensionary claims created a continuing cause of action was not accepted to defeat the express limitation bar. The Tribunal should have first decided limitation as a preliminary issue rather than proceeding to the merits.

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Issues: Whether the original application before the Tribunal was barred by limitation under Section 21 of the Administrative Tribunals Act, 1985, and whether the Tribunal could entertain the challenge to the punishment order on merits.

Analysis: Section 21(1)(a) mandates that an application must be filed within one year from the date of the final order. The punishment order was passed and communicated in 2007, but the original application was filed only in 2015, long after the statutory period. The deceased employee did not challenge the order during his lifetime, and no sufficient cause was shown to justify condonation under Section 21(3). The plea that pensionary claims constituted a continuing cause of action was not accepted for bypassing the express limitation bar. Since the application was time-barred, the Tribunal ought to have decided the preliminary question of limitation instead of proceeding to the merits.

Conclusion: The original application was barred by limitation and could not have been entertained on merits; the Tribunal's order was unsustainable.

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