Authorities must adjudicate trained-teacher pay claims through reasoned orders after granting petitioners an opportunity of hearing.

The 23 petitioners, serving as assistant teachers, headmasters and headmistresses in schools in Bhagalpur, challenged Memo No. 1577 dated 7 May 2026 issued by the Director, Primary Education, Bihar.

They alleged that the memo was arbitrary, contrary to law, and inconsistent with the judgment in Manoj Kumar & Ors. v. State of Bihar & Ors., CWJC No. 7938 of 2020, concerning the grant of trained teacher pay-scale benefits from the dates of successful completion of training rather than from publication of the training results.

The petitioners also relied on Kishor Kumar & Ors. v. State of Bihar & Ors., CWJC No. 16165 of 2019, and stated that the judgment in CWJC No. 7938 of 2020 had been affirmed in LPA No. 456 of 2021 on 3 April 2025 and thereafter by dismissal of the respondents’ Special Leave Petition on 15 January 2026.

Although the petitioners had submitted representations to the District Programme Officer (Establishment), Bhagalpur, no effective action had been taken.

With the parties’ consent, the High Court disposed of the writ petition at the admission stage.

Whether the petitioners’ claim for trained teacher pay-scale and consequential monetary benefits was governed by the principles laid down in Manoj Kumar and Kishor Kumar, particularly regarding entitlement from the date of successful completion of training rather than publication of results.

Whether the petitioners were entitled to a direction requiring the competent authority to consider and decide their individual claims through reasoned and speaking orders.

Whether Memo No. 1577 dated 7 May 2026 was liable to be quashed as arbitrary, illegal and contrary to the binding judicial directions relied upon by the petitioners.

The Court applied the principle that claims for service-related monetary benefits must be adjudicated by the competent administrative authority in accordance with binding judicial precedent and on the basis of the employee’s individual service record.

It relied upon the earlier decision in Manoj Kumar & Ors. v. State of Bihar & Ors., CWJC No. 7938 of 2020, as well as Kishor Kumar & Ors. v. State of Bihar & Ors., CWJC No. 16165 of 2019, concerning the claimed entitlement to trained teacher pay-scale benefits from the date of successful completion of training.

The Court further applied the administrative-law requirement that an authority deciding such claims must provide an opportunity of hearing and pass a reasoned and speaking order.

The Court noted that the petitioners’ substantive claim was stated to be covered by the earlier judgment in Manoj Kumar, which had attained finality after dismissal of the appeal and the subsequent Special Leave Petition.

However, rather than directly determining each petitioner’s entitlement or quashing the impugned memo, the Court accepted the State’s submission that individual representations, supported by service particulars and relevant documents, were necessary for proper adjudication.

The Court therefore directed the competent authority to examine each petitioner’s claim in light of the cited precedents, after granting an opportunity of hearing, and to issue a reasoned and speaking order.

It directed each petitioner to submit an individual representation, along with supporting documents and the relied-upon judgments, to the Director, Primary Education, Bihar, within four weeks from 7 August 2026.

The Director was directed to decide the representations within eight weeks of receipt by passing a reasoned and speaking order after affording an opportunity of hearing.

If the petitioners were found entitled to the claimed relief, the benefits were to be extended within a further four weeks from the date of the final order.

The writ petition was accordingly disposed of, with pending interlocutory applications also disposed of.