Geeta Mishra v. Sidho Kanhu Murmu University
Background
The appellant's husband, a university lecturer, died in service in 1995 after having already exercised his option for the Contributory Provident Fund scheme, and all his retiral benefits were settled accordingly. Years later, the university issued a scheme in 1998 giving employees (or their families, if the employee died before exercising an option) "one more chance" to choose a different retirement-benefits scheme. The appellant, as the widow, sought to use this scheme to claim a fresh option, and a single judge of the Jharkhand High Court ruled in her favour, but a Division Bench reversed that decision on the university's appeal.
Decision Breakdown
The Supreme Court held that the "one more chance" clause in the 1998 scheme was meant only for employees who had died without ever having exercised an option under the earlier statute, not for those, like the appellant's husband, who had already made and acted upon their choice before death. Since the husband had already opted for and received benefits under the Contributory Provident Fund scheme, his widow had no independent right to exercise a second, different option. The Court agreed with the High Court's Division Bench that the scheme's benefit could not be extended to the appellant and found no error in its interpretation of the scheme's terms.
Lesson Learnt
Benefit schemes framed with specific eligibility conditions (such as "one more chance" clauses) will be interpreted strictly according to their actual wording and purpose: a family cannot claim a second opportunity under a scheme if the employee had already validly exercised a choice during their lifetime.