R.K. Yadav v. Union of India
Background
The petitioners, Presiding Officers of the Central Government Industrial Tribunals-cum-Labour Courts (CGIT-cum-LCs) at Delhi and Hyderabad, argued that their tribunals deserved the same 6th Pay Commission pay scales given to bodies like the Central Administrative Tribunal, instead of being pegged to District Judiciary pay scales as recommended by the Justice E. Padmanabhan Committee. They claimed this unequal treatment violated Articles 14 and 16 of the Constitution.
Decision Breakdown
The Supreme Court dismissed the petition, holding that pay fixation is primarily an executive function into which courts exercise only limited judicial review, absent mala fides or a demonstrated anomaly. It found that the petitioners, being re-employed pensioners, formed a distinct class under the Central Civil Services (Fixation of Pay of Re-employed Pensioners) Orders, 1986, which reasonably justified different treatment from regularly serving officers. The Court also noted that CGIT-cum-LCs (other than the National Tribunals at Mumbai and Kolkata) had consistently been equated with the District Judiciary since 1996, following expert recommendations of the Shetty Commission and the Padmanabhan Committee, and that such classification was rational rather than arbitrary.
Lesson Learnt
Courts give substantial deference to expert pay commissions and executive decisions on classifying employees and fixing pay scales; a claim of unequal treatment under Articles 14/16 must show the classification was irrational or made in bad faith, not merely that another arrangement might also have been reasonable.