Delhi High Court

Court-ordered salary arrears, including DA and HRA, attract 6% interest for delayed payment.

Dr Shabana Praveen vs Shri Rajesh Kotecha & Anr.

Delhi High CourtJUDGMENT: July 27, 20263 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The two contempt petitions alleged wilful and deliberate non-compliance with orders dated 27 May 2024 passed in W.P.(C) No. 9584/2018 and W.P.(C) No. 9554/2018.

Source reference: p. 2, para. 1

In those writ proceedings, the Division Bench directed the respondents to release salary to the petitioners for the periods during which they had actually rendered service beyond the age of sixty pursuant to interim orders, subject to verification of their service records and attendance registers.

Source reference: pp. 2–5, paras. 2–3

In Dr Shabana Praveen’s case, salary was directed for the period from 24 January 2018 to 1 June 2020; in Salma Khatoon’s case, salary was directed for the period from 12 September 2018 to 1 June 2020.

Source reference: pp. 2–5, paras. 2–3

The directions were based on the Supreme Court’s order dated 1 June 2020 in Civil Appeal No. 2476/2020, which vacated the interim order permitting continuation in service but directed payment for the period during which the petitioners were found to have actually worked.

Source reference: pp. 2–4, paras. 3–5

The respondents filed additional compliance affidavits.

Source reference: pp. 5–8, paras. 4–5

The petitioners contended that payment had not been made within four weeks of the orders dated 27 May 2024.

Source reference: p. 8, para. 6

The respondents stated that salary, including Dearness Allowance and House Rent Allowance, had been released, but the Court recorded that the amounts were released only in July 2026.

Source reference: p. 8, paras. 7, 10
02

Issues

1. Whether the respondents had complied with the directions dated 27 May 2024 requiring release of the petitioners’ salary, subject to verification of service records and attendance?

Source reference: pp. 2–5, paras. 2–6; p. 8, paras. 6–10

2. Whether the petitioners were entitled to interest on account of delayed release of the amounts directed by the Court?

Source reference: p. 8, paras. 9–11

3. If interest was payable, what rate and period should govern such payment?

Source reference: p. 8, para. 11
03

Law Applied

The Court applied the binding directions contained in the Supreme Court’s order dated 1 June 2020 in Civil Appeal No. 2476/2020, under which an employee who actually rendered service pursuant to an interim order was entitled to salary for that period.

Source reference: pp. 2–4, paras. 3–5

It also applied the specific directions issued by the Division Bench on 27 May 2024, requiring payment within four weeks after verification of the petitioners’ service records, including attendance registers.

Source reference: pp. 2–5, paras. 2–6

The Court treated Dearness Allowance and House Rent Allowance as components of salary rather than as substitutes for or exclusions from the salary obligation.

Source reference: p. 8, paras. 7–8

For delayed payment, it directed payment of interest at 6% per annum from November 2024 until the date of actual release.

Source reference: p. 8, para. 11
04

Reasoning

The respondents’ obligation was not merely to verify the petitioners’ service and release some employment-related payments; the orders expressly required release of salary within four weeks, subject to verification.

Source reference: pp. 2–5, para. 6

Although the respondents claimed to have released salary along with DA and HRA, the Court held that those allowances were components of salary and therefore did not alter the fact that the payment required under the orders was delayed.

Source reference: p. 8, paras. 7–8

Since the amounts were released only in July 2026, substantially after the four-week period, the Court found it appropriate to compensate the petitioners through interest.

Source reference: p. 8, paras. 9–11

Relying on the circumstances of delayed compliance and the claim based on the earlier order dated 9 October 2024, the Court fixed interest at 6% per annum from November 2024 until actual payment.

Source reference: p. 8, paras. 9–11
05

Holding

The Court disposed of both contempt petitions after recording that the principal salary amounts had ultimately been released, albeit belatedly.

It directed the respondents to pay interest at 6% per annum from November 2024 until the date of release of the payment.

Source reference: p. 8, para. 11

The interest component was directed to be released to the petitioners within eight weeks from 27 July 2026.

Source reference: p. 8, para. 12

The petitions were accordingly disposed of.

Source reference: p. 9, para. 13
Delhi High Court

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Dr Shabana PraveenvsShri Rajesh Kotecha & Anr.

Delhi High Court · July 27, 2026

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