Cadre integration precludes salary differentiation based on erstwhile designations for employees performing identical duties and responsibilities.

The respondents were appointed as Live Stock Development Assistants between 1981 and 1986.

Initially, the department had two posts—Live Stock Extension Officer (pay scale 470–735) and Live Stock Development Assistant (pay scale 400–615)—despite both requiring identical qualifications and functions.

Following a Task Force Committee report in 1987, the State merged these posts into a single cadre titled "Live Stock Extension Officer" with retrospective effect from 01.01.1986 via Government Orders (G.O.) dated 03.03.1990 and 05.06.1991.

However, a subsequent G.O. dated 02.04.1992 modified this, granting a higher pay scale of 1350–2200 only to those who held the post prior to 01.01.1986, while keeping the newly merged employees in the 1200–2040 scale.

The respondents challenged this G.O. before a Single Judge, who ruled in their favor. The State filed this Special Appeal against that judgment.

1. Whether the State was justified in prescribing two different pay scales for members of the same unified cadre based on their pre-merger status.

2. Whether the classification introduced by the Government Order dated 02.04.1992 violates the mandate of equality under Articles 14 and 16 of the Constitution.

The Court primarily relied on the constitutional mandates of Articles 14 and 16 regarding equality and non-discrimination.

It applied the principle that any classification must be founded on an "intelligible differentia" having a rational nexus to the object sought to be achieved.

Once cadres are integrated, the earlier separate identity ceases, and the State cannot ordinarily differentiate between members of the same homogenous cadre based on their source of recruitment or erstwhile designation (S. Sivaguru v. State of Tamil Nadu (2013) 7 SCC 335).

The Court reasoned that the objective of the 1990 and 1991 G.O.s was to remove pay disparity between two categories of employees who performed identical duties, as established by the Committee’s findings.

Once the posts were merged into a single cadre with retrospective effect from 01.01.1986, all incumbents formed a "homogeneous class".

The Court rejected the State's argument that the 02.04.1992 G.O. was necessary to protect the interests of senior employees, noting that while seniority matters for promotion, it cannot justify differential pay scales for the same post within the same cadre.

By creating a two-tier pay structure based solely on whether an employee held the title before or after the merger date, the State reintroduced the very disparity it intended to abolish, thereby failing the test of "rational nexus".

The distinction was held to be artificial and arbitrary since the qualifications and duties remained identical.

The Special Appeal was dismissed, and the Single Judge's judgment was affirmed. The Court held that the respondents are entitled to the pay scale of Rs. 1350–2200/- with effect from 01.01.1986. The State authorities were directed to provide all consequential benefits and complete the exercise within three months.