CAT Member Recuses from Forest Officer Plea: 17th Such Instance in 13 Years

Key Highlights & Summary 

• Latest recusal: On September 21, Rajveer Singh Verma, Member (Judicial) of the Central Administrative Tribunal (CAT), Delhi Bench, recused himself from hearing a petition by IFS officer Sanjiv Chaturvedi on his Annual Performance Appraisal Report (APAR). The Registry was directed to list the matter before an appropriate Bench. 

• Pattern of recusals: Over 13 years, 17 judges and judicial officers have stepped aside from cases involving the Uttarakhand-cadre officer. These include two Supreme Court judges, four Uttarakhand High Court judges, nine CAT members and two district judiciary judges.  

• Officer\'s contention: Chaturvedi appeared in person and cited the All India Services (Performance Appraisal Report) Rules, 2007, on the APAR Accepting, Reporting and Reviewing Authorities. The order noted he kept making submissions \'not connected with the issue involved\', despite repeated directions to confine himself to the matter. 

• Earlier instances: In November 2013, then SC judge Justice Ranjan Gogoi recused from a plea seeking a CBI probe into corruption allegations. In February 2024, Justice Manoj Tiwari recused from a case on documents relating to the officer\'s central deputation. 

• Contempt petition: In September-October 2025, Uttarakhand HC judges Alok Verma and Ravindra Maithani recused from a contempt petition alleging wilful disobedience of a HC stay order by CAT members and its Registry.

• Continuing litigation: Chaturvedi, a 2002-batch officer, has been involved in several rounds of litigation over service matters, including postings, disciplinary proceedings, deputation and performance appraisal. 

Essential Definitions 

• Recusal: Voluntary withdrawal of a judge from a case owing to a conflict of interest or a reasonable apprehension of bias. • APAR: Annual Performance Appraisal Report, the official assessment of an officer\'s performance used in promotions and postings. 

• Contempt of court: Wilful disobedience of a court order or conduct that lowers the authority of the court.

 • Bench: A judge or group of judges hearing a case. • Nemo judex in causa sua: Natural justice principle that no person should be a judge in their own cause. 

Legal and Constitutional Framework 

• Article 323A: Empowers Parliament to create administrative tribunals for recruitment and service conditions of public servants. 

• Administrative Tribunals Act, 1985: Establishes the CAT and State Administrative Tribunals, and provides for Judicial and Administrative Members. • Article 226 and Article 227: High Courts\' writ jurisdiction and superintendence over tribunals in their territory. 

• L Chandra Kumar v Union of India, 1997: Tribunal decisions are subject to High Court review, and judicial review is part of the basic structure. 

• Article 14 and Article 21: Fair hearing and impartial adjudication are part of equality before law and due process.

 • Article 311: Safeguards for civil servants against dismissal, removal or reduction in rank without an inquiry. 

• All India Services Act, 1951: Governs the recruitment and service conditions of IAS, IPS and IFS officers.

 • Contempt of Courts Act, 1971: Provides for punishment of civil and criminal contempt.

 • Ranjit Thakur v Union of India, 1987: A reasonable likelihood of bias vitiates proceedings. 

Conclusion Repeated recusals delay justice and strain judicial resources. Clear recusal guidelines, transparent reasons and timely reassignment by the Registry are needed. Officers must use grievance mechanisms responsibly, while the judiciary must safeguard both impartiality and access to justice. 

UPSC Relevance 

• Prelims: Article 323A and Article 323B, CAT composition, natural justice, contempt of court, All India Services.

 • Mains GS-II: Judiciary, tribunals, quasi-judicial bodies, civil services accountability and performance appraisal.

 • Mains GS-IV: Integrity, impartiality, conflict of interest and public service ethics.

 • Essay: Justice delayed and judicial accountability.