CAT - ['Jabalpur']
Employment and Labour LawSocial Security and Pensions

Benefits granted to similarly situated RTP employees must be extended uniformly, including consequential pensionary entitlements.

S R Mishra vs M/o Communications

CAT - ['Jabalpur']JUDGMENT: September 18, 20263 MIN READSOURCE JUDGMENT
Benefits granted to similarly situated RTP employees must be extended uniformly, including consequential pensionary entitlements.. S R Mishra vs M/o Communications. CAT - ['Jabalpur']. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicants, serving or retired employees of the Department of Posts, had initially been selected and trained as Reserved Trained Pool (RTP) personnel for appointment as Postal Assistants.

Source reference: p.3, para. 2

They performed duties comparable to regular Postal/Sorting Assistants and were paid hourly wages, but their services were not counted from the date of RTP appointment for purposes of increments, seniority, promotion, pension, or related benefits.

Source reference: p.3, para. 2

Following abolition of the RTP scheme and their subsequent regularisation, the applicants sought recognition of their RTP service.

Source reference: p.3, para. 1

Their representations were rejected by the Senior Superintendent of Post Offices, Bhopal Division, through orders challenged in the Original Application.

Source reference: p.3, para. 1

The respondents primarily opposed the application on the ground of delay, noting that some applicants had retired and others were nearing retirement.

Source reference: p.4, para. 3

The applicants relied on the Tribunal’s subsequent decision dated 10 July 2026 in O.A. No. 200/256/2019 and connected matters, which had granted similar relief to RTP personnel.

Source reference: p.4, paras. 5–6
02

Issues

1. Whether the applicants were entitled to have their service rendered as RTP personnel counted for consequential service benefits, including seniority, pay fixation, increments, promotion, MACP benefits, and pensionary benefits.

Source reference: pp.3–5, paras. 1–2, 5–6

2. Whether the applicants could be granted the benefit of judgments and Tribunal orders extending similar relief to other similarly situated RTP employees, notwithstanding the respondents’ objection of delay.

Source reference: p.4, para. 3; pp.5–6, para. 12

3. Whether the respondents’ rejection of the applicants’ representations was liable to be reconsidered in light of the Tribunal’s decision dated 10 July 2026.

Source reference: p.7, para. 7
03

Law Applied

The Tribunal applied the principle that similarly situated employees in the same service should not be subjected to different standards and that a judgment granting service benefits may be extended in rem to all similarly situated personnel, without requiring each employee to institute separate proceedings.

Source reference: p.6, para. 12

It relied on the judgment of the High Court for the State of Telangana at Hyderabad in W.P. No. 17400/2016, the Delhi High Court decisions in W.P.(C) Nos. 7301/2025 and 7412/2025, the Principal Bench decisions in O.A. Nos. 4477/2024, 4478/2024 and 610/2025, and the Chhattisgarh High Court decision in WPS No. 1912/2021.

Source reference: pp.5–6, paras. 11–12

These authorities supported extension of the relevant RTP-service benefits, including consequential benefits such as MACP upgradation and pensionary benefits, to similarly placed employees.

Source reference: p.5, para. 11; p.6, para. 13

The Tribunal also noted that the Department had already extended comparable benefits to similarly situated employees in the Hyderabad, New Delhi and Chhattisgarh Regions.

Source reference: p.6, para. 12
04

Reasoning

The Tribunal found that the applicants’ factual position was materially identical to that considered in O.A. No. 200/256/2019 and connected matters decided on 10 July 2026.

Source reference: p.4, para. 6

Since the applicants had rendered service as RTP personnel before regular appointment and had allegedly been denied the same consequential benefits granted to similarly situated employees, the Tribunal held that the earlier decision covered their case.

Source reference: no citation

The Tribunal further relied on the principle that the Department could not adopt different standards for members of the same service or compel every similarly situated employee to litigate separately.

Source reference: p.6, para. 12

Although delay was raised by the respondents, the Tribunal did not treat it as a bar and directed reconsideration of the applicants’ claims in accordance with the earlier order.

Source reference: pp.4, 7, paras. 3, 7
05

Holding

The Original Application was allowed.

The respondents were directed to reconsider the applicants’ cases in terms of the Tribunal’s order dated 10 July 2026 in O.A. No. 200/256/2019 and connected matters, which recognised entitlement to the applicable consequential benefits arising from the treatment of RTP service, including MACP and pensionary benefits.

Source reference: pp.6–7, paras. 13, 7

The reconsideration exercise was ordered to be completed within 90 days from receipt of a certified copy of the Tribunal’s order.

Source reference: p.7, para. 7

There was no order as to costs.

Source reference: p.7, para. 7
CAT - ['Jabalpur']

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S R MishravsM/o Communications

CAT - ['Jabalpur'] · September 18, 2026

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