Received Your APAR Disclosure? The 15-Day Window to Represent

When does the 15-day clock start?

The clock starts on the date the complete APAR, including the overall grading and the remarks of the reviewing and accepting authorities, is disclosed to you. On SPARROW and other online systems, that is the date the report appears in your login for acceptance or representation. If disclosure is by a paper copy, it is the date you received it, which is why you should write the date on your acknowledgement and keep a photocopy.

APAR disclosure is not the same as the report being written. A report may sit completed with the reviewing officer for weeks before it is disclosed, and the 15 days do not run during that time. If you hear informally that your grading is low, you cannot represent yet; wait for formal disclosure, but use the time to gather your papers.

The DoPT instructions speak of 15 days and do not say working days. Treat them as calendar days. If the 15th day falls on a holiday, submitting on the next working day is usually accepted, but do not plan for that. A representation sent on day 13 avoids every argument.

If you were on long leave, on tour or on deputation abroad when the report was disclosed, write down the date you actually saw it and say so in your representation. Offices have generally accepted that the period runs from actual knowledge, but the burden of explaining is yours.

The APAR calendar under the April 2025 OM

What you can ask for in a representation

A representation against an APAR can ask for one or more of three things: that the overall grading be raised, that particular attribute grades be raised, or that a remark in the pen-picture be expunged or modified. You can also object to an entry in the integrity column, though that is rare and needs care.

The most common request is an APAR upgrade request from Good to Very Good, because Very Good is the benchmark for MACP and for promotion to posts at Pay Level 12 and above. Many officers do not represent because a Good grading does not feel adverse. It is not adverse in the ordinary sense, but if it keeps you below a benchmark, the Supreme Court in Dev Dutt (2008) and Sukhdev Singh (2013) treated it as something you are entitled to contest.

You cannot use a representation to argue about posting, workload or your relationship with the officer in general. Keep to what the report says and what your record shows. The representations that succeed point to a specific gap between the grading and the facts, and ask for one clear change.

Who is the competent authority for an APAR representation?

The competent authority for an APAR is designated by each ministry or department. Ordinarily it is an officer senior to the reviewing officer, so that someone who had no hand in writing the report decides the representation. In a large department the APAR cell will tell you who it is; ask if the disclosure letter does not say.

The competent authority usually seeks the comments of the reporting and reviewing officers, if they are still in service and available, before deciding. It then passes an order either upgrading the grading, expunging or modifying remarks, or rejecting the representation. That order should be reasoned. A one-line rejection that does not deal with what you wrote is weak, and paragraph 9.2 of DoPT's DPC guidelines tells a DPC that it need not accept a non-speaking order and should look at the APAR and your representation together.

If the reporting or reviewing officer has since retired, been transferred or is unwilling to comment, the competent authority can still decide on the record. It should not treat the absence of comments as a reason to reject. Equally, it should not upgrade simply because nobody objected; it has to weigh what you have shown against what the report says.

The competent authority is expected to decide within a month of receiving the representation, and the result should reach you by 15 November. In reality decisions are often delayed. If you hear nothing by December, send a short reminder through proper channel and keep a copy.

Writing your representation within the window

Most good representations are written in three or four sittings across the first ten days. Here is the order that works.

1. Day 1: record the date and download everything

   Note the disclosure date, take a screenshot or keep the receipt, and save the full APAR including attribute-wise grades. Read it once without reacting.

2. Days 2 to 4: line up the self-appraisal

   Put your own self-appraisal next to the report. Mark every target you listed and whether the reporting officer accepted, disputed or ignored it. Our guide on writing the self-appraisal explains why this document becomes your best evidence.

3. Days 4 to 7: collect the proof

   Gather appreciation letters, statistics of work done, inspection reports, training certificates and any email from your officers praising specific work. Pick the five or six strongest pieces, not everything.

4. Days 7 to 10: draft the representation

   Address it to the competent authority through proper channel. Say what you want changed, why, and attach the proof. Keep it to two or three pages. Be courteous about the reporting and reviewing officers even where you disagree.

5. Days 10 to 13: submit and get proof

   Submit on SPARROW, or by hand with a dated receipt, or both where your office allows. If there is any doubt about the portal, also send a signed copy to the APAR cell.

6. After 30 days: follow up

   If no decision arrives within the expected time, write a brief reminder. When the order comes, read whether it deals with your points; a reasoned rejection and a non-speaking one lead to different next steps.

The reckoning years used by a DPC are fixed by formula, so a report you represent against now may be read years later. Our guide on how a DPC reads your last five APARs shows which reports will count when.

What makes an APAR upgrade request work

Competent authorities upgrade gradings when the report contradicts itself or contradicts the record. The clearest cases are those where the attribute-wise grades average well above the overall grade, where the pen-picture praises your work but the grading is middling, or where the reviewing officer reduced the grade without giving any reason.

A reporting officer must ordinarily have supervised you for at least three months in the year to write a report. If your officer joined in January and wrote a full-year report, or the report covers a period when you were on deputation or long leave, point that out. Reports written by officers who did not see your work are vulnerable.

What does not work is a representation that attacks the reporting officer, alleges bias without proof, or simply says you deserved better. Competent authorities read many such letters and reject most of them. Advocate B.K. Singh's practice when reviewing a draft representation is to strike out every sentence about the officer's motive and keep only sentences about the work. In his view, a representation that stays on the record makes it easier for the competent authority to upgrade without appearing to censure a colleague.

If you genuinely believe the report was written out of malice, for instance after you complained against the officer, say so once, factually, with the dates and documents. Then leave it. The tribunal can examine mala fides later if needed, but only on proof.

APAR representation time limit: mistakes made inside the 15 days

• Accepting on the portal by reflex. SPARROW asks you to accept the report or represent. Some officers click accept on the first day without reading the attribute grades, and then find they have no record of objecting. Read the whole report before you touch either button.
• Copying a template. Many people search for a representation APAR format and copy one from the internet. Competent authorities recognise these at once. A template cannot speak about your targets, your officer's joining date or your appreciation letter, which are the only things that move a grading.
• Writing directly to the Secretary or the Minister. A representation must go through proper channel to the competent authority. Bypassing the channel can be treated as a breach of the conduct rules under DoPT's instructions, and it rarely speeds anything up.
• Mixing in other grievances. Transfer requests, pending allowances and complaints about colleagues have no place in an APAR representation. They dilute the point and give the authority an easy reason to reject.
• Asking for everything. Asking to raise every attribute and expunge every remark signals that you dispute the whole report. Pick the overall grade and the two or three entries that matter most.
• Submitting on day 15 by an uncertain route. Portals fail, dak gets delayed and clerks go on leave. If you submit at the last moment, use two routes and keep proof of both.

What to attach to the representation

Adverse remarks and the integrity column

An adverse remark is different from a low grading. Words such as 'not reliable', 'avoids responsibility' or 'needs constant supervision' can follow you into vigilance clearances and deputation selections, not just DPCs. A representation against an adverse remark should ask for it to be expunged, and should answer the specific allegation with specific facts.

Reporting officers are expected to have pointed out shortcomings to you during the year, before writing them into a report. If a remark comes as a surprise, with no memo, warning or email earlier in the year, say so. A remark that appears for the first time in the annual report, about conduct nobody raised at the time, is harder for the department to defend.

The integrity column is the most sensitive part of the report. DoPT's instructions expect a reporting officer who doubts an employee's integrity to follow a separate procedure rather than simply writing a doubtful entry, and any such entry should rest on material. If yours says anything other than beyond doubt, take advice before you represent, because the wording of your reply may be read in any later vigilance proceeding.

Where a remark relates to an incident that is also the subject of a chargesheet or inquiry, keep the APAR representation brief and avoid saying anything you would not want read out in the inquiry. The two processes are separate, but the papers travel between them.

Missed the 15 days: what is still possible?

The APAR representation time limit is meant to be firm, because the whole process is supposed to close by 30 November. Even so, a short delay with a good reason is often entertained in practice, especially where you can show you were away, unwell or did not actually see the report. Write a representation anyway, put the reason for delay in the first paragraph, and attach proof. The worst outcome is a rejection on the ground of delay, which leaves you no worse off.

If the report was never disclosed to you at all, the window has not started. That is common for older ACRs written before 2008-09, which were not disclosed unless adverse. DoPT's instructions after Dev Dutt require below-benchmark gradings in such old reports to be communicated, with an opportunity to represent, before a DPC relies on them. If a DPC has already used an undisclosed report against you, our page on APARs graded below benchmark and never shown to you explains the remedy.

Where the delay is long, measured in years, the competent authority is unlikely to reopen the report on its own. The issue then usually comes up when a DPC or MACP screening relies on it, and the tribunal looks at whether you had a fair chance to represent. Do not rely on that. The window exists so that this argument never has to be made.

Rejected: the next step

Most ministries treat the competent authority's decision as the end of the APAR process at the departmental level. There is no regular appeal against it in the way there is against a penalty. Your options after a rejection are to keep the record ready for when the report is used, or to approach the Central Administrative Tribunal against the rejection itself.

Before deciding, ask for the comments the reporting and reviewing officers gave on your representation, and the note on which the competent authority acted. You can request them from the APAR cell or through RTI. These papers often show whether the authority actually considered your points or simply accepted the reporting officer's reply. A rejection that rests only on 'the reporting officer stands by his assessment' is weaker than it looks.

If the grading will clearly affect a promotion or MACP that is coming up, file within one year of the rejection order, because Section 21 of the Administrative Tribunals Act counts from the final order. Our guide on the one-year clock after a final order explains the arithmetic. Waiting until a DPC uses the report is sometimes accepted, but the department will argue delay.

The tribunal will not regrade you itself. What it does is set aside an unreasoned rejection, direct fresh consideration, or direct that a report written in breach of the rules be ignored. Where a DPC has already met, a review DPC follows; see our page on asking for a review DPC after an APAR upgrade.

Group C staff, railways and All India Services

Group C employees also receive APARs and have the same 15-day right to represent, though in many offices the report is still disclosed on paper rather than online. Since Group C promotions below Level 12 need a Good benchmark, the representations that matter most are against Average gradings and adverse remarks. MACP, however, needs Very Good at every level, so a Group C employee nearing the 10, 20 or 30-year mark should treat a Good grading seriously; our guide on MACP refused for APAR benchmark explains why.

Railway employees follow Railway Board instructions on APARs, which track the DoPT scheme on disclosure and representation. Postal staff, defence civilians and employees of autonomous bodies notified under Section 14(2) generally follow the DoPT pattern or a close copy of it.

Officers of the IAS, IPS and Indian Forest Service are governed by the All India Services (Performance Appraisal Report) Rules, 2007, which have their own procedure and timelines. CAT still hears their disputes. CAPF personnel follow their force's appraisal rules and go to the High Court; armed forces officers go to the Armed Forces Tribunal.

Where a challenge is filed

An Original Application against an APAR decision is filed before the CAT bench with jurisdiction over the place where you are posted or where the order was passed. Joseph in our example would go to the Ernakulam Bench; an officer in a Delhi ministry would go to the Principal Bench.

If the APAR has already been used by a DPC to supersede you, the case becomes a promotion dispute as well, and the juniors promoted ahead of you must be made parties. RTI is often needed to see the minutes first; our guide on RTI for DPC minutes and APARs covers what you can expect.

Time and cost at a glance

One habit that saves trouble later

Advocate B.K. Singh's second tip is simple: represent even when the grading meets your current benchmark, if it will not meet the next one. An officer at Level 10 graded Good may be fine for the next promotion today but will need Very Good for MACP and for posts at Level 12. A report left unchallenged in 2025 can be one of the five a DPC reads in 2030, and by then the 15 days are long gone.

Keep a folder, physical or digital, with every APAR, the disclosure date, your representation and the order on it. Most people cannot find these papers when they finally need them.

Need help with your representation?

If you want a second reading of your APAR and draft representation before day 15, send us the disclosed report and your self-appraisal. For a report already used against you, our page on below-benchmark APAR cases sets out what can be done at the DPC and tribunal stage.

For advice on your APAR papers, or for updates on the APAR rules, contact Advocate B.K. Singh.