Chhattisgarh High Court
Employment and Labour LawAdministrative and Public Law

Authorities must individually determine eligibility for ad hoc increments through a reasoned order.

KRISHNA KUMAR SHUKLA vs THE CHHATTISGARH STATE POWER TRANSMISSION COMPANY LTD.

Chhattisgarh High CourtJUDGMENT: September 09, 20263 MIN READSOURCE JUDGMENT
Authorities must individually determine eligibility for ad hoc increments through a reasoned order.. KRISHNA KUMAR SHUKLA vs THE CHHATTISGARH STATE POWER TRANSMISSION COMPANY LTD.. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The nine petitioners, employees/former employees associated with the Chhattisgarh State Power Companies, sought a direction to the respondents to grant them a 15% ad hoc increase on their basic pay from the date of their initial appointment, together with arrears, consequential benefits, and interest at 6%.

Source reference: para. 1

They also sought implementation of the judgment of the High Court of Madhya Pradesh in Sanjay Chourey & Others v. M.P. Power Management Co. Ltd. & Others, WA No. 1714 of 2019, decided on 07 November 2025.

Source reference: para. 2

The petitioners asserted that the Madhya Pradesh decision recognised the entitlement of Class-III employees to ad hoc increments at par with Class-I, Class-II, and Class-IV employees, and that the decision had been affirmed by dismissal of SLP No. 7772 of 2026 by the Supreme Court on 13 March 2026.

Source reference: para. 2

During hearing, the petitioners requested consideration of their pending representation, Annexure P/6, in light of those decisions.

Source reference: paras. 2–4
02

Issues

Whether the petitioners’ claim for a 15% ad hoc increase and consequential arrears was covered by the judgment in Sanjay Chourey and the subsequent order of the Supreme Court dismissing the SLP.

Source reference: para. 2

Whether the competent authority should be directed to consider and decide the petitioners’ representation in accordance with the aforesaid judgments.

Source reference: paras. 4–6

Whether the High Court should itself grant the claimed monetary and consequential benefits at the writ stage.

Source reference: paras. 4–6
03

Law Applied

The Court applied the principle that where an issue has been addressed in a binding or persuasive precedent, the competent administrative authority must consider an applicant’s claim in the light of that precedent, while independently examining whether the applicant is factually covered by it.

Source reference: paras. 2, 4–6

The Court relied upon the judgment of the High Court of Madhya Pradesh in Sanjay Chourey & Others v. M.P. Power Management Co. Ltd. & Others, WA No. 1714 of 2019, which, according to the petitioners’ submission, held that Class-III employees were entitled to ad hoc increments at par with Class-I, Class-II, and Class-IV employees, including arrears.

Source reference: para. 2

It also noted the Supreme Court’s dismissal of SLP No. 7772 of 2026 arising from that decision.

Source reference: para. 2

The Court did not determine the substantive entitlement of the petitioners and preserved the respondents’ power to examine each case on its individual facts and in accordance with law.

Source reference: paras. 5–6
04

Reasoning

Since the petitioners relied on an apparently applicable decision concerning entitlement to ad hoc increments and the Supreme Court had dismissed the consequential SLP, the Court considered it appropriate for the competent authority to first examine the petitioners’ representation in the light of those decisions.

Source reference: paras. 2–4

However, the Court did not automatically extend the benefit to the petitioners; it directed the authority to determine individually whether they were covered by the Sanjay Chourey judgment and to pass a reasoned and speaking order.

Source reference: para. 5

The Court expressly declined to adjudicate the merits of the claim or to direct immediate payment of arrears and other benefits.

Source reference: para. 6
05

Holding

The writ petition was disposed of in limine.

The competent authority was directed to consider and decide the petitioners’ representation, Annexure P/6, in the light of the Madhya Pradesh High Court’s judgment in Sanjay Chourey and the Supreme Court’s order, within 60 days from receipt of the High Court’s order along with the relevant documents.

Source reference: paras. 4–5

The authority was permitted to examine each petitioner’s case individually and to grant the benefit if the petitioner was found to be covered by the precedent.

Source reference: para. 5

The Court clarified that it had expressed no opinion on the merits and that the decision must be made strictly in accordance with law and on the individual merits of each case.

Source reference: para. 6
Chhattisgarh High Court

Original Court PDF

KRISHNA KUMAR SHUKLAvsTHE CHHATTISGARH STATE POWER TRANSMISSION COMPANY LTD.

Chhattisgarh High Court · September 09, 2026

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment