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State of M.P. & Ors. v. Mala Banerjee

Civil Appeal · Neutral citation not assigned (Civil Appeal No. 2944 of 2015)Decided 17 Mar 2015
Civil Appeal No. 2944 of 2015
Justice Vikramajit Sen · Justice Prafulla C. Pant

Background

A large batch of appeals by the State of Madhya Pradesh challenged High Court rulings that upheld the right of teachers/lecturers in the Education and Tribal Welfare Department to the "Kramonnati Scheme": a policy granting two higher pay scales on completion of 12 and 24 years of service. The State wanted to give teachers this second higher pay scale only from 1.8.2003, while the teachers claimed it from 19.4.1999 (the date the Scheme was introduced for other employees), and the State had even initiated recovery proceedings against teachers paid from the earlier date.

Decision Breakdown

The Supreme Court held there was no rational basis to treat teachers differently from other government employees for the Kramonnati Scheme's benefit, calling it discriminatory and arbitrary and a violation of Articles 14 and 16 of the Constitution. The Court rejected the State's argument that this was a non-justiciable policy matter, noting courts can strike down policies that are arbitrary, irrational, or unconstitutional. It found the High Court's judgment (upholding the teachers' claim from 19.4.1999) correct and dismissed all the appeals (and connected applications) without imposing costs.

Lesson Learnt

A government cannot arbitrarily carve out one class of employees (here, teachers) for less favourable treatment under a general benefit scheme without a rational justification, doing so violates the constitutional guarantee of equality, and courts will strike down such discriminatory policy decisions even when framed as administrative/financial policy.

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

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