Rajasthan Agricultural University, Bikaner (Through its Registrar) vs. Dr. Zabar Singh Solanki and Ors.
Background
Research Assistants at a Rajasthan agricultural university were, over the years, re-designated first as Lecturers and later as Assistant Professors, and were given the same pay-scale as directly-recruited Lecturers/Assistant Professors. When the Government of India introduced a Career Advancement Scheme (CAS) in 1988 giving a higher "senior scale" to teachers who completed eight years of service after "regular appointment," these re-designated staff claimed the CAS benefit too, but the State Government objected that the scheme was meant only for those directly and regularly appointed as Assistant Professors. The employees won before a Single Judge and a Division Bench of the Rajasthan High Court, prompting the University's appeals to the Supreme Court.
Decision Breakdown
The Supreme Court held that Research Assistants and Lecturers/Assistant Professors are separate, distinct cadres (as an earlier 1985 order of the Court had already clarified), and that mere re-designation to an equivalent post is not the same as a "regular appointment" to that post. Since the CAS scheme specifically restricted its senior-scale benefit to persons with eight years of service counted from regular appointment, the re-designated employees (and, in a connected appeal, those counting ad-hoc service before their regular appointment) were not entitled to CAS benefits, even though they already drew the same pay-scale as direct recruits. The Court set aside the High Court's orders but, balancing equities, directed that no money already paid be recovered from the employees, and that their pay be reckoned only notionally for retiral purposes without the CAS benefit.
Lesson Learnt
Being placed on the same pay-scale as another cadre through re-designation does not automatically extend every subsequent scheme or benefit meant specifically for regularly/directly appointed staff: eligibility conditions written into a policy (like "years of service after regular appointment") must be read and applied literally, not stretched by equity alone.