Madhya Pradesh High Court

### Classified permanent employees are entitled to arrears of minimum pay scale until the adoption of the 2016 State policy.

Shyam Lal Rajak v. The State of Madhya Pradesh and Others [2026:MPHC-JBP:18908]

Madhya Pradesh High CourtJUDGMENT: no citation3 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, Shyam Lal Rajak, was classified as a permanent employee on October 29, 2011.

Source reference: para. 7.2

He filed this writ petition seeking a Mandamus to compel respondent No. 3 to pay him the minimum of the pay scale (Rs. 5200–20200 + Grade Pay Rs. 1900) and arrears of salary from the date of his classification.

Source reference: para. 7.2

The state contended that the petitioner had already accepted the benefits of the government policy dated October 7, 2016, which categorized daily wagers into skilled, semi-skilled, and unskilled groups with specific pay scales.

Source reference: para. 2

The state further relied on a coordinate bench decision in Chetan Lal Gupta v. State of M.P. (W.P. No. 39586/2024), which clarified the limits of such claims.

Source reference: para. 2-3
02

Issues

1. Whether a classified permanent employee is entitled to the minimum of the regular pay scale of a post after having accepted the benefits of the State’s categorization policy dated October 7, 2016.

Source reference: para. 2-3

2. Whether the petitioner is entitled to arrears of the minimum pay scale for the period between the date of classification and the date the 2016 policy was implemented.

Source reference: para. 2
03

Law Applied

The court applied the principle established in Ram Naresh Rawat v. Ashwini Ray & others (2017) 3 SCC 436, which held that classified employees are entitled to the minimum of the pay scale of the post, but not the increments or regular status.

Source reference: para. 2, 3

It further integrated the doctrine from Chetan Lal Gupta and others v. State of M.P. (W.P. No. 39586/2024), which posits that once an employee opts for the specific pay scales provided under the State Policy dated October 7, 2016, they cannot claim a higher regular pay scale, though they remain entitled to arrears for the interval preceding the policy.

Source reference: para. 3
04

Reasoning

The court reconciled the petitioner’s claim with the 2016 State Policy and prior precedents.

Source reference: no citation

It noted that the 2016 scheme was formulated for daily wagers who could not be regularized under the Uma Devi (2006) guidelines; thus, the categorization (skilled/unskilled) determines the wages from the date of the policy onwards.

Source reference: para. 3

Applying the Chetan Lal Gupta reasoning, the court found that the petitioner’s demand for the minimum pay scale of a specific post (Rs. 5200–20200) was "misconceived" because he had already transitioned into the 2016 policy framework.

Source reference: para. 3

However, the court distinguished the period prior to the policy's implementation; per Ram Naresh Rawat, the petitioner maintains a valid claim for arrears of the minimum pay scale from the date of his classification (2011) until the date he began receiving benefits under the October 7, 2016 policy.

Source reference: para. 2
05

Holding

The court disposed of the petition by directing the petitioner to file a comprehensive representation to Respondent No. 2 (Engineer-in-Chief, WRD) within ten days.

The court held that while the petitioner cannot claim the regular pay scale moving forward due to the 2016 policy, he is entitled to have his claim for arrears (from the date of classification to the date of policy extension) examined in light of Ram Naresh Rawat.

Source reference: para. 2, 4

The respondents were ordered to pass a speaking order within 90 days, verify if the classification order remains intact, and extend any due benefits accordingly.

Source reference: para. 4

No costs were awarded.

Source reference: para. 5
Madhya Pradesh High Court

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Shyam Lal Rajak v. The State of Madhya Pradesh and Others [2026:MPHC-JBP:18908]

Madhya Pradesh High Court · no citation

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