Chhattisgarh High Court

Absorbed Panchayat teachers are ineligible for Kramonnati benefits reserved for regular School Education Department employees.

TUMMAN LAL PATEL vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: March 30, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The ten petitioners, serving as Lecturers, Teachers, and Assistant Teachers (L.B.) in various Government Schools in District Kanker, were initially appointed by the Janpad Panchayat under the Panchayat Department

Source reference: para. 1, 3

Pursuant to a State policy decision dated 30.06.2018, they were subsequently absorbed into the School Education Department

Source reference: para. 3, 5

The petitioners filed this writ petition seeking a direction for the grant of Kramonnati Vetanmaan (Time Pay Scale) upon the completion of 10 years of continuous service, placing reliance on a State Government circular dated 10.03.2017 and the Division Bench judgment in Smt. Sona Sahu v. State of Chhattisgarh (W.A. No. 261/2023)

Source reference: para. 1.2, 2

The State opposed the petition, arguing that as former Panchayat employees governed by separate rules, the petitioners did not qualify as regular employees of the School Education Department for the period claimed

Source reference: para. 3
02

Issues

1. Whether the petitioners, having been initially appointed under the Panchayat Department and later absorbed into the School Education Department, are entitled to Kramonnati Vetanmaan under the circular dated 10.03.2017

Source reference: para. 1.2, 5

2. Whether the petitioners' case is governed by the precedent set in Smt. Sona Sahu v. State of Chhattisgarh or the Coordinate Bench decision in WPS No. 11009 of 2025

Source reference: para. 2, 3, 5
03

Law Applied

The Court primarily applied the eligibility criteria defined in the State Government Circular dated 10.03.2017 regarding the grant of time pay scales

Source reference: para. 5

It further relied on the principles of statutory governance under the Panchayat Raj Adhiniyam, 1993, which distinguishes Panchayat employees from regular School Education Department staff

Source reference: para. 5

Finally, the Court followed the doctrine of stare decisis by applying the recent Coordinate Bench precedent from WPS No. 11009 of 2025 (decided on 24.11.2025), which addressed identical facts regarding absorbed teachers

Source reference: para. 5, 6
04

Reasoning

The Court examined the petitioners' service history and determined that until their absorption on 30.06.2018, they were categorized as shikshakarmis (Panchayat teachers) and were not employees of the School Education Department

Source reference: para. 5

The Court reasoned that although their designations were changed to Teacher or Lecturer (Panchayat), they remained governed by separate rules framed under the Panchayat Raj Adhiniyam, 1993

Source reference: para. 5

Applying the reasoning from the Coordinate Bench in WPS No. 11009 of 2025, the Court observed that the circular dated 10.03.2017 applies only to regular teachers of the School Education Department

Source reference: para. 5

Since the petitioners did not fulfill these criteria during their tenure under the Panchayat Department, they were ineligible for the benefit

Source reference: para. 5

The Court noted that the petitioners’ counsel did not dispute the factual identity between this case and the dismissed batch of petitions in WPS No. 11009 of 2025

Source reference: para. 4, 6
05

Holding

The Court held that the petitioners are not entitled to the grant of Kramonnati Vetanmaan as they did not meet the criteria of the 10.03.2017 circular prior to their absorption

The Court dismissed the writ petition, maintaining consistency with the order passed in WPS No. 11009 of 2025 dated 24.11.2025

Source reference: para. 6

All requested reliefs, including arrears of pay and interest, were denied

Source reference: para. 1.3, 6
Chhattisgarh High Court

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TUMMAN LAL PATELvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · March 30, 2026

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