Benefits of a judgment in rem must be extended to all similarly situated employees without requiring fresh litigation.

The applicants, serving as Assistant Account Officers and Account Officers across various Postal and Telecommunication departments, sought a pay revision to fix their Grade Pay at Rs. 5400/- under the Modified Assured Career Progression (MACP) Scheme.

They based their claim on a prior judgment delivered by the Tribunal in OA No. 966 & 967 of 2009, which had granted similar benefits to other employees.

The respondents issued impugned orders on April 20, 2015, and June 11, 2015, asserting that the 2009 judgment was restricted to the parties in that specific case and could not be treated as a universal precedent for the entire department.

The applicants challenged these orders, seeking parity and the disbursement of arrears.

1. Whether the benefit of a declaration of law obtained by one set of employees must be extended to all other similarly situated persons regardless of whether they were parties to the original litigation.

2. Whether the judgment in OA No. 966 & 967 of 2009 regarding MACP benefits constitutes a judgment in rem or a judgment in personam.

The court primarily relied on the principles of equality under Article 14 of the Constitution of India, emphasizing that treating identically situated persons differently amounts to discrimination.

It applied the precedent from State of Uttar Pradesh & Ors. v. Arvind Kumar Srivastava (2015), which established that the normal rule in service jurisprudence requires benefits granted by a court to be extended to all similarly situated employees unless barred by laches, delay, or acquiescence.

The court further integrated the doctrine from Lt. Col. Suprita Chandel v. Union of India (2024) and Amrit Lal Berry v. Collector of Central Excise (1975), which hold that a government department should extend the benefit of a judicial declaration to all similarly situated citizens without forcing each individual to approach the court.

The Tribunal examined the nature of the MACP Scheme, noting it was introduced via the 6th Central Pay Commission to apply across all departments effective September 1, 2008.

Because the MACP is a broad policy matter rather than a personal grievance, the Tribunal reasoned that any judicial decision regarding its implementation is a judgment in rem intended for universal application within the relevant class of employees.

The court noted that the 2009 judgment did not expressly prohibit its extension to non-parties; consequently, the respondents' refusal to apply the precedent to the applicants was found to be discriminatory and violative of Article 14.

While the legal principle of entitlement was affirmed, the court clarified that the department must still conduct an individual exercise to ensure each applicant meets the specific performance criteria (such as ACR benchmarks) required for MACP benefits.

The respondents were directed to extend the benefits of the 2009 judgment to the applicants, provided they satisfy the eligibility conditions for the grant of MACP, with the exercise to be completed within four months of the order.