Distinct educational qualifications and duties justify disparate pay scales, negating claims for parity under "equal pay for equal work."

The 21 applicants are Marketing Officers and Senior Marketing Officers (Groups I and III) within the Directorate of Marketing Inspection (DMI)

Historically, Marketing Officers in Groups I, II, and III shared identical pay scales until 2000

On 21.02.2000, the Government upgraded the pay scale of Group II to Rs. 8000–13500, while Groups I and III remained at Rs. 6500–10500

Following the 6th Central Pay Commission (CPC), Group II was placed in PB-3 with a Grade Pay (GP) of Rs. 5400, whereas Groups I and III were placed in PB-2 with a GP of Rs. 4600

The applicants challenged the rejection order dated 17.04.2015, alleging discrimination and seeking parity with Group II

The respondents contended that Group II is a specialized cadre requiring a Bachelor of Veterinary Science degree and performs distinct duties related to livestock and meat products

1. Whether the denial of pay parity to Marketing Officers (Groups I III) with Marketing Officers (Group II) violates the principle of "equal pay for equal work"

2. Whether the difference in educational qualifications and specialized functional requirements constitutes a valid legal basis for maintaining distinct pay scales

The Tribunal primarily applied the doctrine of "equal pay for equal work" as derived from Articles 14 and 39(d) of the Constitution of India

It relied on the precedent in State of Madhya Pradesh v. Pramod Bhartiya (1993), which held that the doctrine is inapplicable if a classification is reasonable and possesses a nexus to the objective sought to be achieved

The Tribunal further cited Dr. C. Girijambal v. Govt. of Andhra Pradesh (1981), stating the principle is inapplicable to professional services

Sohan Singh Sodhi v. Punjab Electricity Board (2007), which affirmed that educational qualifications are a valid ground for pay differentiation

The Tribunal observed that while Groups I and III involve general agricultural marketing, Group II requires specialized qualifications (B.V.Sc. AH) and registration with the Veterinary Council of India, making them comparable to General Duty Medical Officers

This educational distinction justifies the grant of a higher pay scale and Non-Practicing Allowance (NPA) to Group II

The Tribunal reasoned that the nature of work—meat and livestock export quality control for Group II versus general agricultural duties for Groups I and III—is not identical

It further noted that the Group II cadre in DMI is a "dying cadre" with its functions largely transferred to the Ministry of Food Processing Industry, rendering the applicants' comparison with a nearly non-existent post infructuous

Consequently, the Tribunal held that mere historical parity prior to the 5th CPC does not entitle the applicants to future parity when recruitment rules and responsibilities differ

It concluded that the classification based on higher educational qualifications and distinct job responsibilities was proper and reasonable

The impugned order dated 17.04.2015 was upheld, and no relief was granted to the applicants