D.Ravichandran vs The State of Tamil Nadu
- Court
- Madras High Court
WP(MD). No.24663 of 2025
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT
RESERVED ON : 27.02.2026
DELIVERED ON : 03.07.2026
CORAM
THE HONOURABLE MR. JUSTICE B.PUGALENDHI
WP(MD)No.24663 of 2025
and
WMP(MD)Nos.19357, 19358, 23344 of 2025
D.Ravichandran ... Petitioner
Vs
1.The State of Tamil Nadu,
Rep. by its Secretary to Government,
School Education Department,
Fort St.George,
Chennai – 600 009.
2.The Director of Elementary Education,
O/o.Director of Elementary Education,
College Road,
Chennai – 6.
3.The District Educational Officer (Elementary),
O/o.District Educational Office,
Trichy, Trichy District.
4.The District Educational Officer (Elementary,
O/o.District Educational Office,
Madurai, Madurai District.
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5.The Block Educational Officer,
O/o.Block Educational Office,
Thathaiyangarpettai Block,
Trichy District.
6.The Block Educational Officer,
O/o.Block Educational Office,
Kottampatti Block,
Madurai District. ... Respondents
Writ Petition filed under Article 226 of the Constitution of India,
praying this court to issue a Writ of Certiorari to call for the records
pertaining to the Impugned Order of the fifth respondent in Na.Ka.No.
830/A1/2017 dated Nil.07.2018 and the consequential order of the sixth
respondent in Na.Ka.No.1009/A1/2024 dated 18.11.2024 and quash the
same.
For Petitioner : Mr.H.Mohammed Imran
for M/s.Ajmal Associates
For Respondents : Mr.M.Sarangan,
Additional Government Pleader
*
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ORDER
The petitioner is serving as a Secondary Grade Teacher at the
Panchayat Union Middle School, Kunnarampatty, Kottampatty Block,
Madurai. He was initially appointed as a Secondary Grade Teacher at
the Panchayat Union Elementary School, Melakottangal,
Thathaiyangarpettai Block on 01.02.1999. He was granted incentive
increments for acquiring M.A. (Economics) and B.Ed. degrees with effect
from 11.07.2013. However, pursuant to an audit objection that the
petitioner had been wrongly granted incentive increment for acquiring
the M.A. (Economics) degree, the fifth respondent, after putting the
petitioner on notice, revised his pay. Thereafter, the sixth respondent, by
proceedings dated 18.11.2024, directed recovery of the excess amount
paid towards the incentive increment. Challenging the said
communications, the present writ petition has been filed.
2.Learned Counsel appearing for the petitioner submitted that
GO.Ms.No.624, Education Department, dated 13.07.1992 imposed certain
conditions for grant of incentive increments to teachers acquiring higher
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qualifications. According to him, those conditions were subsequently
removed by GO.Ms.No.324, Education, Science and Technology
Department (E2), dated 25.04.1995, which provided that Secondary
Grade Teachers would be entitled to incentive increments for acquiring
qualifications in relevant Higher Secondary syllabus subjects. It was
contended that the said Government Order continues to hold the field
and that M.A. (Economics) is undoubtedly a qualification in a relevant
Higher Secondary syllabus subject. Therefore, the petitioner was rightly
granted incentive increment. It was further submitted that the impugned
revision of pay was based on the proceedings of the second respondent
dated 24.08.2016, whereas the petitioner had been granted incentive
increment as early as in the year 2013. According to the learned counsel,
the subsequent proceedings cannot retrospectively deprive the petitioner
of a benefit already conferred. It was also argued that the clarification
issued by the second respondent cannot override G.O.Ms.No.324.
3.In support of his submissions, the learned counsel for the
petitioner relied upon the following decisions:
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(i) Government of Tamil Nadu rep. by its Secretary v.
G.Saraswathi [ W.A.No.2747 of 2023 dated 28.03.2025 ]; and
(ii) V.Gnana Christal Ida v. State of Tamil Nadu [ W.A.(MD)No.
2748 of 2025 etc., batch dated 09.01.2026 ].
4.Per contra, the learned Additional Government Pleader
appearing for the respondents submitted that the petitioner was granted
incentive increment for acquiring M.A. (Economics) contrary to the
governing Government Orders and that the mistake came to light only
during audit. Consequently, the petitioner's pay was revised and
recovery was ordered. He submitted that GO.Ms.No.324 contemplates
grant of incentive increments only for acquiring qualifications in
relevant Higher Secondary syllabus subjects. Referring to the
clarification issued by the second respondent in proceedings dated
24.08.2016, he submitted that incentive increments are admissible only
for qualifications in subjects such as Science, Mathematics, Tamil,
English and Social Science. According to him, the qualification of M.A.
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(Economics) has no relevance to the duties discharged by the petitioner
as a Secondary Grade Teacher and would not advance the object
underlying the scheme of incentive increments.
5.In support of his submissions, the learned Additional
Government Pleader relied upon the following decisions of this Court:-
(i) S.Thangathai v. Director of School Education [ W.A.(MD)No.918
of 2015 dated 17.12.2015 ]; and
(ii) R.Sakthivel v. The Secretary to Government, Education
Department [ W.A.(MD)No.910 of 2022 dated 24.08.2022 ].
6.This Court has considered the rival submissions and perused the
materials available on record.
7.The petitioner is serving as a Secondary Grade Teacher. He was
granted incentive increments for acquiring M.A. (Economics) and B.Ed.
degrees with effect from 11.07.2013. Pursuant to an audit objection, it
was found that the petitioner had been wrongly granted incentive
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increment for acquiring the M.A. (Economics) qualification. Accordingly,
the respondents revised the petitioner's pay and directed recovery of the
excess amount paid towards the incentive increment. Therefore, the
entitlement of the petitioner to incentive increment for acquiring the
M.A. (Economics) qualification has to be examined in the light of the
Government Orders governing the field.
8.GO.Ms.No.324, Education, Science and Technology Department
(E2), dated 25.04.1995 provides that incentive increments may be granted
to Secondary Grade Teachers for acquiring qualifications in relevant
Higher Secondary syllabus subjects. The petitioner contends that since
Economics forms part of the Higher Secondary syllabus, he is entitled to
the benefit under the said Government Order. However, the expression
"relevant Higher Secondary syllabus subjects" cannot be construed in
isolation. The relevance contemplated under the Government Order
must necessarily be with reference to the duties discharged by the
teacher concerned. If the expression is interpreted to mean that every
Secondary Grade Teacher acquiring a postgraduate qualification in any
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Higher Secondary syllabus subject automatically becomes entitled to an
incentive increment, it would result in grant of incentive increments
even for qualifications having no nexus with the teaching functions
discharged by such teachers. Such an interpretation would defeat the
very object of the scheme.
9.It is also relevant to note that the Government issued GO.Ms.No.
907, Personnel and Administrative Reforms (FR.II) Department, dated
17.09.1986, wherein it was clarified that the higher qualification should
relate to the area of specialisation in the subject normally taught by the
employee and not merely to any higher qualification. Further, by
proceedings dated 24.08.2016, the second respondent clarified that
incentive increments would be admissible only for acquiring
qualifications in subjects such as Science, Mathematics, Tamil, English
and Social Science. Therefore, GO.Ms.No.324 cannot be read in isolation
and has to be understood in the light of GO.Ms.No.907 and the
clarification issued by the second respondent.
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10.It is relevant to note that the concept of incentive increment did
not originate as a service benefit attached to every higher qualification
acquired by a Government servant. Rather, it emerged as a policy
measure intended to encourage Government servants to acquire
specialised knowledge and qualifications that would enhance their
efficiency in public service. In the case of teachers, the Government
recognised that acquisition of higher qualifications would improve the
quality of classroom instruction and ultimately strengthen the education
system. It is for this reason that the Government introduced the scheme
of incentive increments to teachers through GO.Ms.No.42, Education
Department, dated 10.01.1969.
11.An incentive, by its very nature, is a reward extended by the
employer to encourage excellence, improve efficiency, or promote the
acquisition of knowledge and skills that advance the interests of public
administration. The Cambridge English Dictionary defines the
expression "incentive" as "something that encourages a person to do
something by offering them a reward." The definition itself indicates that an
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incentive is intended to encourage a desired course of action by
rewarding it. Therefore, the grant of an incentive increment cannot be
treated as an automatic entitlement merely because a Government
servant has acquired a higher educational qualification.
12.Black's Law Dictionary (2nd Edition) defines "incentive
compensation" as "payments in excess of agreed wages; a bonus and profit
sharing as an incentive for good performance." Though the definition arises
in the context of employment law, it reinforces the principle that an
incentive is linked to the benefit expected by the employer and not
merely to the possession of an additional qualification. In the case of
teachers, the knowledge and skills acquired through the higher
qualification must have a direct bearing on the teaching duties
discharged by them and should ultimately enure to the benefit of the
students. Mere acquisition of an additional qualification, without any
corresponding educational benefit to the students or the institution,
cannot, by itself, confer a right to claim an incentive increment.
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13.Applying the above principles to the facts of the present case,
this Court finds that the petitioner is serving as a Secondary Grade
Teacher teaching students at the elementary and middle school level.
Though Economics is one of the subjects in the Higher Secondary
syllabus, that by itself does not entitle the petitioner to claim incentive
increment. The qualification of M.A. (Economics) has no direct or
reasonable nexus with the duties ordinarily discharged by the petitioner
as a Secondary Grade Teacher. The petitioner has not established that the
additional knowledge acquired by him through the said qualification
would benefit the students taught by him or fulfil the object for which
the scheme of incentive increments was introduced. Therefore, this
Court holds that the petitioner is not entitled to incentive increment for
acquiring the M.A. (Economics) qualification under GO.Ms.No.324,
Education, Science and Technology Department (E2), dated 25.04.1995.
14.The above conclusion also stands fortified by the decisions of
this Court. A Division Bench of this Court in S.Thangathai v. Director of
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School Education [ W.A.(MD)No.918 of 2015 dated 17.12.2015 ] explained
the object of granting incentive increments to teachers in the following
words:
"6. It is quite unfortunate that the object of grant of advance
incentive increment to Teachers, is many times lost sight of. The
object is to encourage Teachers to pursue higher education, so that the
higher education that they pursue enures to the benefit of the
students. In this case, the appellant is a Physical Education Teacher.
We do not know how the acquisition of a Under Graduate Degree in
History and Post Graduate Degree in History would have enured to
the benefit of the students, especially from a Physical Education
Teacher."
The Division Bench thus emphasised that the object of the scheme is not
merely to reward acquisition of higher qualifications, but to ensure that
the higher qualification acquired by the teacher ultimately enures to the
benefit of the students.
15.Similarly, another Division Bench of this Court in R.Sakthivel v.
The Secretary to Government, Education Department and Others [ W.A.
(MD)No.910 of 2022 dated 24.08.2022 ] held that the object of granting
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incentive increments is to encourage teachers to acquire qualifications
that would be beneficial to the students. The relevant observations read
as follows:
"13. The appellant submitted that the object of granting
incentive increment is to lift the morale of the teachers. But the
Government states that the object of granting incentive increment is
to encourage the Teachers to qualify themselves, so that their
qualification would be beneficial to the students. In the present case
the petitioner was working as Secondary Grade Teacher taking class
for students from 1 to 5 standards and the qualification of M.Sc.
Physics would not be beneficial to the students studying in the
standards 1 to 5. Therefore, the Government is right in denying the
incentive increment for higher qualifications when the higher
qualification is not beneficial for the students studying in the
standards 1 to 5."
The principle laid down by the Division Bench squarely applies to the
facts of the present case.
16.This Court has also taken a similar view in Arul Rani v. State of
Tamil Nadu [ W.P.(MD)No.15098 of 2020 dated 16.03.2023 ], wherein
recovery of the incentive increment granted to a Secondary Grade
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Teacher for acquiring M.A. and M.Phil. qualifications was upheld. This
Court observed as follows:
"15. ... An incentive must be a reward to encourage a worker,
who is performing better than the others. It must be depending upon
the performance and not on possession of any degree alone."
The above observation succinctly brings out the true nature of an
incentive increment and fully supports the view taken by this Court in
the present case.
17.Therefore, it must be understood that an incentive increment
must always remain linked to the object for which it was introduced.
Thus, the continuance of such an incentive must necessarily be
supported by a corresponding justification. It is also relevant to note that
the Government has, by GO.Ms.No.37, Personnel and Administrative
Reforms (FR-IV) Department, dated 10.03.2020, taken a policy decision
to abolish the scheme of recurring advance and incentive increments for
acquiring higher educational qualifications. However, many Teachers
continue to receive incentive increments granted under the earlier policy.
It must be borne in mind that the amount paid towards such incentive
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increments is taxpayer's money. Such expenditure can be justified only
so long as it continues to advance the object for which the incentive was
introduced. Therefore, the Government is directed to devise an
appropriate mechanism to periodically assess whether those Teachers,
who continue to receive incentive increments, are effectively utilising the
additional knowledge and skills acquired by them in the discharge of
their teaching duties so as to benefit the students. Based on such
assessment, the Government shall take an appropriate decision, in
accordance with law, as to whether the benefit of incentive increments
should continue to be extended to those teachers who are already
receiving the same under the earlier policy.
18.In view of the object underlying the scheme of incentive
increments, the Government Orders governing the field and the
principles laid down in the above decisions, this Court finds no infirmity
in the action of the respondents in revising the petitioner's pay and
directing recovery of the excess incentive increment paid to him.
Accordingly, the writ petition stands dismissed with the above direction.
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Consequently, the connected miscellaneous petitions are closed. There
shall be no order as to costs.
For compliance as to the Government's mechanism to assess the
beneficiaries, list this writ petition on 09.12.2026.
Internet : Yes 03.07.2026
gk
To
1.The Secretary to Government,
State of Tamil Nadu,
School Education Department,
Fort St.George,
Chennai – 600 009.
2.The Director of Elementary Education,
O/o.Director of Elementary Education,
College Road,
Chennai – 6.
3.The District Educational Officer (Elementary),
O/o.District Educational Office,
Trichy, Trichy District.
4.The District Educational Officer (Elementary,
O/o.District Educational Office,
Madurai, Madurai District.
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5.The Block Educational Officer,
O/o.Block Educational Office,
Thathaiyangarpettai Block,
Trichy District.
6.The Block Educational Officer,
O/o.Block Educational Office,
Kottampatti Block,
Madurai District.
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B.PUGALENDHI, J.
gk
WP(MD) No.24663 of 2025
03.07.2026
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