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State of Madhya Pradesh Through Principal Secretary & Ors. vs. Seema Sharma

Civil Appeal · 2022 INSC 560Decided 12 May 2022
Civil Appeal No. 3892 of 2022
Indira Banerjee · C.T. Ravikumar

Background

Seema Sharma was appointed in 1991 as Librarian-cum-Museum Assistant at a Government Ayurvedic College in Ujjain, under rules governing the Ayush (Indian medicine) Department, not the Higher Education Department. After eight years of service she claimed the higher UGC (University Grants Commission) pay scale given to Librarians in Higher Education Department colleges, relying on a 1990 recruitment-rules schedule. The Madhya Pradesh High Court (Single Judge and Division Bench) ruled in her favour, directing the State to pay her the UGC scale from her date of appointment.

Decision Breakdown

The Supreme Court allowed the State's appeal and set aside the High Court's orders. It held that the 1990 Rules (which prescribed the UGC scale) applied only to Higher Education Department colleges, whereas Sharma's post was governed by separate 1987/2013 Rules applicable to the Ayush Department, which never extended UGC scales to its employees. The Court reiterated that "equal pay for equal work" requires identical eligibility criteria, recruitment mode and duties, mere similarity of designation is not enough, and that pay-scale fixation is a policy matter courts should not disturb absent clear discrimination between similarly-situated employees. Since Ayurvedic college librarians were governed by a distinct set of rules with different qualifications than Higher Education Department librarians, there was no unlawful discrimination.

Lesson Learnt

An employee cannot claim a better pay scale simply because another employee with a similar job title receives it: the courts will look closely at whether the two posts share the same recruitment rules, qualifications and duties before finding discrimination.

Official source (sci.gov.in)View Judgment (PDF)

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