Authorities must accord identical trained-pay benefits when employees’ claims are covered by binding precedent.

The 60 petitioners were initially appointed as Panchayat Teachers or Prakhand Teachers under the Bihar Panchayat Elementary Teacher (Appointment and Service Conditions) Rules, 2012, in various districts of Bihar.

They were subsequently deputed for in-service Diploma in Elementary Education training for the 2015–17 and 2016–18 sessions. Although the training had been completed earlier, the examination was conducted in October–November 2018 and the results were published on 19 January 2019.

The petitioners claimed entitlement to the trained scale/grade pay from the date of completion of training, relying on the judgment in Manoj Kumar & Ors. v. The State of Bihar & Ors., C.W.J.C. No. 7938 of 2020, decided on 1 February 2021.

That decision was stated to have been affirmed after dismissal of L.P.A. No. 456 of 2021 and SLP No. 66035 of 2025.

They also sought implementation of Clause 4(C)(i) of the Bihar State Litigation Policy, 2011, concerning internal settlement of claims covered by existing court judgments.

Whether the petitioners, having completed the prescribed teachers’ training, were entitled to the trained scale/grade pay from the date of completion of training in terms of Manoj Kumar & Ors. v. The State of Bihar & Ors.

Whether the petitioners’ claims were required to be considered by the Director, Primary Education, in accordance with Clause 4(C)(i) of the Bihar State Litigation Policy, 2011, where their cases were identical to those already granted relief.

The Court applied the Bihar Panchayat Elementary Teacher (Appointment and Service Conditions) Rules, 2012, under which the petitioners had been appointed as Panchayat or Prakhand Teachers.

It relied principally on the binding legal position declared in Manoj Kumar & Ors. v. The State of Bihar & Ors., C.W.J.C. No. 7938 of 2020, regarding entitlement to the trained scale/grade pay from the date of completion of training; that decision had been affirmed upon dismissal of the relevant intra-court appeal and special leave petition.

The Court also invoked Clause 4(C)(i) of the Bihar State Litigation Policy, 2011, which requires the concerned department to settle internally an employee’s claim when it is covered by an existing court judgment.

The governing principle was that identically situated employees must receive identical relief where their claims fall within the scope of an affirmed judicial decision.

The Court found that the petitioners’ pleaded circumstances—appointment as elementary teachers, completion of in-service training, and delayed examination and publication of results—were substantially similar to the circumstances considered in Manoj Kumar.

Since the precedent relied upon by the petitioners had attained finality after dismissal of the appeals, their claim required consideration in light of that settled legal position rather than through fresh litigation on the same issue.

However, instead of directly granting the trained scale, the Court directed the petitioners to submit separate representations so that the competent authority could verify each petitioner’s individual service and training particulars.

The Director, Primary Education was required to decide the representations in accordance with the precedent and the Litigation Policy, and to grant the same relief if the claims were found to be identical to those of employees who had already received it.

Upon receipt, the Director was directed to consider and conclude the representations preferably within a further period of eight weeks, keeping in view Manoj Kumar, the Court’s observations, and Clause 4(C)(i) of the Bihar State Litigation Policy, 2011.

The Court expressly directed that, if the petitioners’ claims were identical to those of employees already granted the benefit, identical relief must also be granted to them.