Delayed disbursement of research fellowship without bona fide grounds warrants payment of interest to the claimant.

The petitioner was appointed as a Junior Research Fellow (JRF) in a DBT-funded research project at the College of Agriculture, Tripura, via an appointment letter dated 02.07.2018

His service was extended periodically through March 2021

While he received his monthly fellowship (Rs. 25,000 + 10% HRA) until November 2019, the respondents withheld payments for the period from 01.12.2019 to 14.01.2021 (totaling 13 months and 14 days) without assigned reasons

After the petitioner filed the present writ petition, the respondents released the principal amount of Rs. 4,69,172/- on 02.05.2025 but did not include any interest for the delay

1. Whether the petitioner is entitled to receive interest on the delayed payment of his fellowship amount which was withheld by the respondents without bona fide grounds

The court applied the equitable principle of restitution and the law of Mandamus, holding that when a statutory or contractual payment is withheld by authority without justified grounds, negligence, or fault on the part of the recipient, the authority is liable to pay interest for the period of delay

The court exercised its discretionary power under Article 226 to grant interest as a compensatory measure for "delayed payment"

The court examined the respondents' contention that the delay was due to "technicalities" rather than intentional laches

However, the court noted that the respondents' counter-affidavit failed to demonstrate any fault, negligence, or breach of duty on the part of the petitioner that would justify the withholding of his JRF fellowship

Since the respondents admitted the liability by releasing the principal amount (Rs. 4,69,172/-) only after the initiation of legal proceedings in May 2025, the court determined that the petitioner suffered an unjustified deprivation of funds

Consequently, the court held that the respondents were liable for statutory interest to mitigate the financial loss caused by the delay from the date the payment became due until the date of actual disbursement

The High Court partly allowed the writ petition and directed the respondent authorities to pay interest at the rate of 6% per annum on the total amount of Rs. 4,69,172/- calculated from 01.12.2019 to 02.05.2025 within three months from the date of the judgment