Madhya Pradesh High Court

Entitlement to Notional Annual Increment for Pensionary Benefits Accrued upon Superannuation on 30th June.

Vishnu Prasad vs Divisional Railway Manager

Madhya Pradesh High CourtJUDGMENT: July 29, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, Vishnu Prasad, was an employee under the Divisional Railway Manager who superannuated from service on 30.06.2024

Source reference: para. 2

He filed this writ petition under Article 226 of the Constitution of India seeking a mandamus to direct the respondents to grant him one annual increment that became due on 01.07.2024, the day immediately following his retirement

Source reference: para. 1-2

The petitioner further sought consequential benefits including pay fixation, pension revisions, arrears, and interest at 12%

Source reference: para. 1

The respondents contended that the matter is strictly governed by recent Supreme Court precedents regarding the cut-off dates for such benefits

Source reference: para. 3
02

Issues

1. Whether a retired employee is entitled to an annual increment that falls due on the day following their superannuation

Source reference: para. 2, 7

2. Whether the petitioner is entitled to interest on the arrears of such increment and pensionary benefits

Source reference: para. 1, 6
03

Law Applied

The court applied the principles established by the Supreme Court of India in Union of India v. M. Siddaraj (Misc. Application Diary No. 2400/2024 in Civil Appeal No. 3933/2023), which stipulated that while the entitlement to one increment for those retiring on June 30th is recognized, the financial benefits (pension increase) are payable only from 01.05.2023 for third parties, and arrears for those filing petitions are limited to three years prior to the date of filing

Source reference: para. 5

Furthermore, the court relied on Madhya Pradesh Purv Kshetra Vidyut Vitran Company Ltd. v. Vidyut Mandal Pension Samaj & Ors. (SLP (C) No. 16679/2025), which clarified that interest is not to be awarded on these specific arrears

Source reference: para. 6
04

Reasoning

The High Court examined the timeline of the petitioner’s retirement (30.06.2024) and the due date of the increment (01.07.2024)

Source reference: para. 2

It noted that the legal entitlement to such an increment is no longer res integra following the Supreme Court's ruling in M. Siddaraj.

Source reference: para. 5

the court observed that the Supreme Court had issued specific restrictive directions regarding the period from which the enhanced pension is payable to avoid excessive retrospective financial burdens

Source reference: para. 5

Regarding the claim for 12% interest, the court reasoned that since the Supreme Court in Vidyut Mandal Pension Samaj specifically set aside High Court orders granting interest on such arrears, the petitioner’s claim for interest must be denied to maintain uniformity with the apex court's mandate

Source reference: para. 6-7
05

Holding

The High Court disposed of the petition by holding that the petitioner is entitled to the increment benefit subject to the specific terms and conditions laid down in M. Siddaraj and Vidyut Mandal Pension Samaj

The court effectively granted the inclusion of the increment for pension calculation but denied any interest on the arrears, directing the respondents to process the benefits in accordance with the cited Supreme Court guidelines

Source reference: para. 7
Madhya Pradesh High Court

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Vishnu PrasadvsDivisional Railway Manager

Madhya Pradesh High Court · July 29, 2026

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