Administrative correction of unauthorized pay scales does not violate natural justice if benefits were void ab initio.

The petitioner was appointed as a Senior Technical Assistant at Vikram University in 1994.

In 2007, the University, purportedly exercising discretion under a State Government order dated 15.12.1999, re-designated his post to "Technical Officer" and enhanced his pay scale from Rs. 1600–2720 to Rs. 8000–13500.

In 2012, nine employees were promoted to Assistant Registrar; the petitioner challenged his exclusion, claiming entitlement based on his re-designated status.

Subsequently, in 2017, the State Government directed the University to cancel the 2007 pay scale and re-designation, asserting they were granted without mandatory prior sanction.

The petitioner was shifted back to his original lower pay scale and post, which he challenged in the connected writ petition on grounds of violation of natural justice.

1. Whether the University was legally justified in re-designating the petitioner’s post and enhancing his pay scale without prior State Government approval.

2. Whether the cancellation of the pay scale and subsequent demotion violated the principles of natural justice and were thus sustainable in law.

3. Whether the petitioner is entitled to be considered for promotion to the post of Assistant Registrar.

The Court primarily applied the provisions of the M.P. Vishwavidyalaya Adhiniyam, 1973, which mandates prior State Government permission for the creation, up-gradation, or re-designation of posts.

It relied on the principle that statutory discretion must be exercised reasonably and within the limits of the law, citing Mansukhlal Vithaldas Chauhan v. State of Gujarat (1997).

It relied on the principle that statutory discretion must be exercised reasonably and within the limits of the law, citing U.P. State Road Transport Corpn. v. Mohd. Ismail (1991).

Regarding natural justice, the Court applied the doctrine from Prakash Ratan Sinha v. State of Bihar (2009), distinguishing it to clarify that natural justice cannot be used to perpetuate a benefit that was void ab initio or illegal.

The Court found that the State’s 1999 order did not explicitly authorize the re-designation of "Senior Technical Assistant" to "Technical Officer" nor the specific pay hike to Rs. 8000–13500; it merely allowed universities to decide on revised scales at their own expense.

The University exercised its discretion mechanically and capriciously by granting a significant financial upgrade without the mandatory statutory sanction required under the Adhiniyam.

Since the foundation of the petitioner’s claim (the re-designated post) was arbitrary and unauthorized, the State’s corrective action in 2017 was legally valid.

The Court further reasoned that natural justice is not a tool to protect benefits derived via illegality.

Regarding promotion, the Court noted that under the 2017 Gazette Notification, the feeder cadre for Assistant Registrar is "Senior Superintendent," a post the petitioner never held, thus disqualifying him on statutory grounds.

The petitioner’s claim for promotion was rejected as he lacked the statutory feeder-cadre qualification.

However, balancing equities, the Court directed that no recovery shall be made from the petitioner regarding the excess salary already disbursed during the period he held the erroneously enhanced pay scale.