CAT - ['Delhi']
Employment and Labour LawSocial Security and Pensions

Delayed retirement gratuity attracts compound interest at applicable GPF rates; financial constraints are no defence.

Satish Chandra Gautam vs MUNICIPAL CORPORATION OF DELHI

CAT - ['Delhi']JUDGMENT: August 13, 20262 MIN READSOURCE JUDGMENT
Delayed retirement gratuity attracts compound interest at applicable GPF rates; financial constraints are no defence.. Satish Chandra Gautam vs MUNICIPAL CORPORATION OF DELHI. CAT - ['Delhi']. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, a retired employee of the Municipal Corporation of Delhi (MCD), sought payment of ₹16,99,744 towards retirement gratuity, together with statutory interest for delayed payment and penal interest at 18% per annum.

Source reference: para. 1

During the pendency of the Original Application, the MCD paid the retirement gratuity to the applicant by order dated 9 August 2024, which payment was acknowledged by the applicant.

Source reference: paras. 2–3

The surviving dispute concerned the applicant’s entitlement to interest on the delayed payment of gratuity.

Source reference: para. 4

The MCD opposed the claim, contending that the delay resulted from circumstances beyond its control and financial constraints.

Source reference: para. 4
02

Issues

Whether the applicant was entitled to interest on the delayed payment of retirement gratuity after the principal gratuity amount had been released.

Source reference: paras. 3, 6

Whether the interest payable on the delayed gratuity was required to be calculated at the applicable GPF rate on a compound-interest basis.

Source reference: para. 7

Whether the MCD’s plea of financial constraints could defeat the applicant’s claim for interest on delayed retiral dues.

Source reference: para. 8
03

Law Applied

The Tribunal applied the principle stated by the Full Bench of the Central Administrative Tribunal in Rajbir Singh v. Municipal Corporation of Delhi & Another, O.A. No. 2821/2023, decided on 30 October 2025, that interest is payable on delayed payment of GPF, pension, gratuity and other retiral dues at the applicable GPF rate for the relevant years, and that such interest is to be calculated on a compound-interest basis.

Source reference: para. 3

The applicant had also relied upon Rule 65 of the CCS (Pension) Rules, 2021 concerning interest on delayed payment of gratuity.

Source reference: para. 1

The Tribunal further held that the employer’s financial constraints, by themselves, do not disentitle a retired employee from receiving interest on delayed retiral benefits.

Source reference: para. 8
04

Reasoning

Once the MCD paid the principal amount of retirement gratuity, the only surviving issue was the applicant’s entitlement to interest for the period of delay.

Source reference: para. 6

The Tribunal treated the Full Bench decision in Rajbir Singh as directly governing the issue and found no reason to adopt a different view.

Source reference: para. 7

Applying that precedent, it held that the delayed gratuity was to carry interest at the applicable GPF rate, calculated on a compound basis.

Source reference: para. 7

The MCD’s explanation that the delay resulted from financial constraints was insufficient to extinguish the applicant’s accrued entitlement to interest.

Source reference: para. 8
05

Holding

The Tribunal held that the applicant was entitled to compound interest on the delayed payment of retirement gratuity at the applicable GPF rate, in accordance with the Full Bench ruling in Rajbir Singh.

The MCD was directed to release the requisite interest within eight weeks from the date of receipt of a copy of the order.

Source reference: para. 9

The Original Application was accordingly disposed of, with no order as to costs; any pending miscellaneous applications were also disposed of.

Source reference: paras. 10–11
06

Acts & Sections Cited

1 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

Administrative Tribunals Act, 19851

CAT - ['Delhi']

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Satish Chandra GautamvsMUNICIPAL CORPORATION OF DELHI

CAT - ['Delhi'] · August 13, 2026

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