सं Samvidhan

The Constitution of India

Article 323A

Administrative tribunals

Why this exists

Article 323A was added by the 42nd Constitutional Amendment in 1976, during a period when courts were flooded with service-related litigation by government employees, causing long delays. The idea, drawn from recommendations of administrative reform bodies, was to create specialised, faster tribunals staffed with people familiar with service law, taking such disputes out of the regular court hierarchy so employees could get quicker justice and courts could focus on other matters.

How courts read it

Parliament used this power to enact the Administrative Tribunals Act, 1985, creating the Central Administrative Tribunal (CAT) and State Administrative Tribunals. The exclusion of court jurisdiction under clause (2)(d) was challenged as removing judicial review, a part of the Constitution's 'basic structure'. In S.P. Sampath Kumar v. Union of India (1987), the Supreme Court upheld the tribunals but insisted they must have judicial-quality members and effectively substitute for High Courts. Later, in L. Chandra Kumar v. Union of India (1997), a seven-judge bench held that completely excluding the High Courts' power of judicial review under Articles 226 and 227 was unconstitutional, since judicial review by the High Courts and Supreme Court is part of the basic structure. As a result, tribunal decisions remain subject to scrutiny by a Division Bench of the jurisdictional High Court, even though clause (2)(d) literally says otherwise.

Common misconceptions
  • Myth: Once a tribunal decides a service dispute under Article 323A, no court can ever review it, because clause (2)(d) says so.
    Fact: The Supreme Court in L. Chandra Kumar v. Union of India (1997) held that High Courts retain the power to review tribunal decisions under Articles 226/227, because judicial review is part of the basic structure — so the exclusion in clause (2)(d) cannot be applied literally.
  • Myth: Article 323A applies to all government litigation.
    Fact: It applies only to disputes about recruitment and conditions of service of public servants, not to other kinds of disputes involving the government.