Entitlement to Notional Increment for Pensionary Benefits on Retiring a Day Before Accrual

The applicant, Pritpal Singh, retired as Assistant Director from the Sports Authority of India on 30.06.2014 upon attaining the age of superannuation

He sought the grant of one additional notional increment, which he earned during his final year of service, for the purpose of calculating his pension and seeking resultant enhanced pensionary benefits

The respondent (Sports Authority of India) rejected his claim via a letter dated 23.06.2025

Consequently, the applicant filed the present Original Application (OA) challenging the rejection and seeking implementation of the benefit effective from 01.05.2023 in light of Supreme Court precedents

1. Whether a government servant who retires on 30th June or 31st December is entitled to a notional increment earned during the preceding year for the purpose of pensionary benefits

2. Whether the applicant is entitled to arrears of pension based on the notional increment and for what specific period

The principle established by the Hon’ble Supreme Court in The Director (Admin and HR) KPTCL Ors vs. C.P. Mundinamani Ors, which held that the entitlement to an increment crystallizes upon completion of a year’s service with good conduct, becoming "payable" on the succeeding day even if the employee has retired; to deny this would be arbitrary

Supreme Court’s directions in Union of India Anr. v. M. Siddaraj (2025), which clarified that for employees filing petitions after the judgment, the increment is reckoned for pension calculation, and for those who filed earlier, arrears are limited to three years prior to the date of filing

DoPT Office Memorandum (O.M.) dated 20.05.2025, which standardized the grant of notional increments for pensionary purposes

The Tribunal observed that the legal issue regarding notional increments on the last day of retirement is no longer res integra (already decided) due to the KPTCL judgment

The court analyzed the timeline of the applicant's retirement (30.06.2014) and the subsequent legal developments. It integrated the specific modified directions from the M. Siddaraj case, noting that while the increment must be granted to those retiring on 30th June/31st December, it is strictly for "calculating the pension admissible" and not for other pensionary benefits

The Tribunal noted that the DoPT had already issued instructions to all departments on 20.05.2025 to comply with these judicial mandates. Therefore, the applicant’s claim required re-examination by the respondents through the lens of these updated legal principles rather than the summarily rejected letter of June 2025

The respondents were ordered to complete this exercise within three months from the date of receipt of the certified copy of the order. No costs were awarded