Karnataka Rural Infrastructure Development Limited v. T.P. Nataraja & Ors.

Civil Appeal · 2021 INSC 521Decided 21 Sept 2021
Civil Appeal No. 5720 of 2021
Justice M.R. Shah · Justice A.S. Bopanna

Background

An employee of a Karnataka state corporation, whose service record showed his date of birth as 04.01.1960 based on his school certificate, asked 24 years after joining to have it changed to 24.01.1961. When the corporation refused, he sued and won in the trial court's appellate stage: the Karnataka High Court declared his date of birth as he wanted, reasoning he may not have known of a 1991 corporation resolution adopting a law that required such requests within strict time limits. The corporation appealed to the Supreme Court. A connected case, where another employee's similar request had been rejected after the corporation was told to reconsider it in light of the same High Court ruling, was heard together.

Decision Breakdown

The Supreme Court held that ignorance of law is no excuse, as an employee of the corporation, the respondent was expected to know the applicable service rules, so the High Court was wrong to excuse his 24-year delay on that basis. Relying on a long line of its own precedents, the Court reiterated settled principles: a request to correct date of birth must follow the specific rules in force, cannot be claimed as of right even with good supporting evidence, and can be rejected for delay and laches, especially when made at the fag end of service. Applying this, the employee's request should have been rejected for gross delay and the High Court's judgment could not stand in law. However, since the correction had already been implemented and the employee had since retired on the corrected date, the Court declined to undo that outcome for him personally: it only decided the legal question in the corporation's favour for future use, and treated the connected appeal as already resolved since that employee's renewed request had separately been rejected and upheld.

Lesson Learnt

Employees cannot wait decades, especially until near retirement, to seek correction of their recorded date of birth and then claim it as an automatic right; courts will weigh delay and laches heavily against such late claims, and "I didn't know the rule" is not a valid excuse for an employee bound by it.

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