Delayed GPF payment mandates statutory interest, regardless of administrative fault.

The applicant, Sanjay Anand, voluntarily retired from service as a Superintendent from CGST, Gautam Buddha Nagar Commissionerate on February 11, 2023.

Despite his Pension Payment Order being issued on February 10, 2023, the final settlement of his General Provident Fund (GPF) was not made on the date of retirement.

After repeated follow-ups, including lodging a grievance on August 1, 2023, and communication from PAO Noida indicating reminders for online processing of the GPF claim, the final GPF balance of ₹24,05,239/- was eventually paid on December 2, 2023, approximately nine months after his retirement, but without interest for the delayed period.

The applicant's subsequent grievance seeking interest was rejected by an order dated December 19, 2024.

The respondents contended that the delay was due to an internal audit objection raised on February 20, 2023, regarding excess pay fixation of the applicant, correspondence for waiver of recovery, and procedural requirements between the Commissionerate and PAO Noida, including online submission through PFMS.

They further argued that in cases of voluntary retirement, the process differed from superannuation requiring manual processing.

1. Whether the applicant is entitled to interest on the delayed payment of General Provident Fund (GPF) in terms of Rule 11(4) of the General Provident Fund (Central Services) Rules, 1960.

2. Whether the impugned order dated December 19, 2024, rejecting the applicant's claim for interest on delayed GPF payment, is sustainable.

The court primarily applied Rule 11(4) of the General Provident Fund (Central Services) Rules, 1960, which mandates that interest shall be payable up to the end of the month preceding that in which payment is made, or up to the end of the sixth month after the amount became payable, whichever is less, with a provision for competent authority approval for interest beyond six months.

Additionally, Rule 34 of the same Rules casts a statutory duty on the Accounts Officer for prompt payment.

The court also referred to Government of India O.M. No. 3/3/2016-P&PW(F) dated January 16, 2017, and O.M. No. 3/7/2024-P&PW(F)(10139) dated October 25, 2024, which reiterate the mandatory nature of interest payment on delayed GPF.

Judicial precedents, including Vijay L. Mehrotra v. State of U.P. (2001) 9 SCC 687, were cited, affirming the liability to award interest for delayed payment of retiral benefits.

The Full Bench decision of this Tribunal in Rajbir Singh v. Municipal Corporation of Delhi (OA No.2821/2023, decided on 30.10.2025) allowed interest on delayed GPF at the applicable rate for administrative delay.

Ramesh Kumar v. State of Punjab (CWP -31472/2024, decided on 19.12.2024) from the Punjab & Haryana High Court was also referenced, confirming entitlement to interest for delayed statutory dues where no justifiable reason exists.

The Tribunal found that the GPF amount, though payable on the date of retirement (February 11, 2023), was disbursed after approximately nine months (December 2, 2023).

The respondents' explanations for the delay, including an audit objection, inter-departmental correspondence, and procedural requirements, were deemed administrative factors that did not absolve them of the statutory obligation to pay interest.

The Tribunal underscored that the applicant had no role in such administrative processes, and the statutory scheme for interest payment is not contingent upon determining inter se responsibility between department wings.

Rule 11(4) does not make negligence a condition precedent for interest payment but rather contemplates it when payment is not made on the due date.

Relying on the consistent jurisprudence that retiral benefits are vested rights and delay in payment without sufficient reason is a breach of statutory obligation, the Tribunal concluded that the administrative and procedural delays did not justify withholding interest.

The impugned order dated December 19, 2024, was quashed and set aside.

The respondents were directed to calculate and release simple interest on the delayed GPF payment to the applicant at the rate applicable to the General Provident Fund for the relevant financial years covering the period of delay, in terms of Rule 11(4) read with Rule 34 of the aforesaid Rules.

The calculation must cover the period from the date the amount became payable until the date of actual payment, subject to the statutory framework governing interest payment beyond six months.

The claim for compound interest @18% was rejected.

The exercise is to be completed within three months from the receipt of the order.