Patna High Court

Claim for Arrear Salary Barred by Delay and Laches Arising from Unconditional Acceptance of Regularization Conditions

Dr. Rajendra Prasad vs The State of Bihar

Patna High CourtJUDGMENT: June 04, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner was appointed to a non-teaching post in 1982 by a private Managing Committee and was subsequently absorbed by the State Government in 1995

Source reference: p.2

Following a Screening Committee review, the Health Department ordered his relief in May 2003, followed by a formal termination order dated August 29, 2003

Source reference: p.3-4

After extensive litigation (CWJC No.10301 of 2003 and LPA No.1155 of 2005), a Review Committee found his appointment genuine

Source reference: p.4-5

Consequently, the State issued a notification on October 17, 2007, re-absorbing him with effect from June 1, 1986, but Clause 10 of said order specified that no arrears would be paid for the period he was out of service

Source reference: p.5, 10

The petitioner accepted this order, worked until his retirement on June 30, 2020, and filed the present writ in 2022 seeking arrears for the period 2003–2007

Source reference: p.6, 10
02

Issues

1. Whether the petitioner is entitled to arrears of salary for the period between his termination and re-absorption (29.08.2003 to 31.10.2007) despite the restrictive Clause 10 in the absorption order

Source reference: p.2 / para. 11

2. Whether the writ petition is barred by the doctrine of delay and laches given it was filed 14 years after the cause of action

Source reference: p.7 / para. 14

3. Whether the petitioner can claim parity with similarly situated employees (e.g., Bishram Ojha) who received arrears

Source reference: p.5 / para. 12
03

Law Applied

The Court applied the principle of "delay and laches," which precludes relief to litigants who sleep over their rights for an inordinate period

Source reference: p.10

The Court relied on State of Uttar Pradesh & Ors. v. Arvind Kumar Srivastava & Ors. regarding the denial of parity to "deadwood" or "tardy" litigants who approach the court late

Source reference: p.7

The Court applied the precedent from State of Orissa v. Pyarimohan Samantaray & Ors., establishing that making repeated representations does not provide a satisfactory explanation for delay

Source reference: p.11

The Bihar State Litigation Policy, 2011, Clause 4.C(1) regarding parity was considered but found inapplicable to the petitioner's specific procedural history

Source reference: p.6
04

Reasoning

The Court noted that the 2007 absorption notification explicitly stated in Clause 10 that the period of absence would count for pension but not for salary arrears

Source reference: p.10

The petitioner accepted this condition without protest and continued service for 13 years until retirement in 2020

Source reference: p.10

The Court reasoned that the petitioner "woke up" to file the writ only 14 years after the order and 17 months after retirement, making the claim stale

Source reference: p.10-11

Regarding parity with Bishram Ojha, the Court distinguished the cases because Ojha had continuously and actively pursued his legal remedies through multiple specific writ petitions and appeals, whereas the petitioner remained silent

Source reference: p.11
05

Holding

The Court held that the petition was severely hit by delay and laches, and the petitioner, having accepted the 2007 absorption terms for over a decade, could not challenge them post-retirement

The Court dismissed the writ application, holding that the petitioner failed to make out a case for payment of salary arrears

Source reference: para. 29-30
Patna High Court

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Dr. Rajendra PrasadvsThe State of Bihar

Patna High Court · June 04, 2026

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