Completion of computer certificate from recognized government university entitles employees to additional increment under state circular.

The petitioner, an Assistant Grade-III employee, obtained prior departmental permission in 1995 to undergo computer training

He successfully completed a six-month "Advance Professional Certificate in Office Automation" from Jiwaji University, Gwalior

On 06.02.2006, the State Government issued a circular mandating computer training and providing for one additional increment to employees possessing such qualifications

The petitioner’s representation for this increment was initially ignored, leading to a prior writ petition (W.P. No. 5188/2010), where the Court directed the respondents to decide the matter

On 21.09.2016, the respondents rejected the representation via a non-speaking order, claiming the petitioner did not fulfill the circular's conditions without specifying which ones

The State contended that the training was from a non-approved/private institute and that the recruitment rules were amended in 2008, making computer literacy mandatory for the post

1. Whether the petitioner is entitled to one additional increment pursuant to the State Government circular dated 06.02.2006 for possessing a computer certificate from a recognized university

2. Whether the rejection of the petitioner’s representation by the respondents vide order dated 21.09.2016 was arbitrary and legally sustainable

State Government Circular dated 06.02.2006, specifically Para 9, which entitles employees with computer training to one additional increment

Madhya Pradesh Rajya Bima Sevayen Tritiya Shreni (Arajpatrit) Seva Ke Sadasyon Ki Bharti Tatha Seva Sharton Se Sambadhit Niyam, 2008

Administrative law principle that orders affecting the rights of parties must be "speaking orders" (reasoned) to avoid being struck down as arbitrary

The court found that the petitioner had obtained the qualification from Jiwaji University, a government-recognized institution approved by the UGC, long before the 2008 Rules were enacted

The court dismissed the State's argument regarding "unapproved institutions" because the respondents failed to produce any list of excluded institutions or demonstrate that Jiwaji University was incompetent to issue the certificate

The court noted that since the petitioner acquired the qualification prior to the 2008 Rules, the mandatory requirement of the new rules did not bar the incentive increment provided by the 2006 circular

Crucially, the court found the impugned rejection order dated 21.09.2016 to be non-speaking and arbitrary, as it failed to assign specific reasons or identify which condition of the circular the petitioner failed to meet

The Court held that the petitioner is entitled to the increment as per the 2006 circular. The respondents were directed to: (i) release one increment from the date of the circular (06.02.2006); (ii) pay all arrears and consequential benefits within three months; and (iii) pay interest @6% per annum from the date of entitlement. Due to the respondents' conduct in passing a non-speaking order in a second round of litigation, the court heightened the interest rate to 12% per annum if the payment is not made within the stipulated three-month period