CAT - Allahabad

Executive policy restricting discretionary relaxation of pension qualifying service is immune from judicial review.

RAM SUMER vs POST UP CIRCLE

CAT - AllahabadJUDGMENT: March 24, 20263 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant served as a Gramin Dak Sevak (GDS) from 10.02.1972 until his promotion to a regular Group ‘D’ post on 06.02.1997

Source reference: p. 2

He retired on 31.10.2006, having completed 9 years, 8 months, and 21 days of regular service

Source reference: p. 3

Under the CCS (Pension) Rules, 1972, a minimum of 10 years of qualifying service is mandatory for pension

Source reference: p. 3

Even after applying a permissible 3-month relaxation under Rule 49(3), the applicant’s service totaled 9 years, 11 months, and 21 days, falling short by 9 days

Source reference: p. 3/5

Following a 2019 Supreme Court directive in UOI v. Gandiba Behera, the Postal Services Board (PSB) issued a policy decision on 25.09.2020 stating that no further relaxation under Rule 88 would be granted beyond the inbuilt 3-month relaxation provided under Rule 49

Source reference: p. 6/7

Consequently, the respondents rejected the applicant's claim for pension via an order dated 17.07.2023

Source reference: p. 2

The applicant challenged this rejection and the underlying PSB policy

Source reference: p. 2
02

Issues

1. Whether the service rendered as a GDS can be counted toward the qualifying service required for regular pension

Source reference: p. 5

2. Whether the Tribunal can quash the Postal Services Board's policy decision to restrict the exercise of discretionary power under Rule 88 of the CCS (Pension) Rules, 1972

Source reference: p. 7/8
03

Law Applied

The court primarily applied the CCS (Pension) Rules, 1972, specifically Rule 49 (qualifying service and standard relaxation) and Rule 88 (power of the Ministry to relax rules in cases of "undue hardship")

Source reference: p. 6

The court relied on the Supreme Court precedent in Union of India v. Gandiba Behera (SLP (C) No. 13042/2014), which established that GDS service is non-pensionable and cannot be added to regular service for pension purposes

Source reference: p. 5

The court applied the principles of judicial restraint in policy matters as laid down in Directorate of Film Festivals v. Gaurav Ashwin Jain (2007), Premium Granites v. State of T.N. (1994), and Balco Employees Union v. Union of India (2001), which hold that courts should not interfere with executive policy decisions unless they are unconstitutional, statutory violations, or manifestly arbitrary

Source reference: p. 8/9
04

Reasoning

The Tribunal observed that the applicant’s regular Group ‘D’ service was mathematically insufficient to meet the 10-year requirement, even with the Rule 49 relaxation

Source reference: p. 5

Regarding the applicant's argument that Rule 88 should be invoked for a 9-day shortfall, the court noted that the Supreme Court in Gandiba Behera explicitly categorized the "Power to Relax" as being within the "decision-making domain of the Executive"

Source reference: p. 8

The Postal Services Board, after due deliberation, formulated a policy to limit such relaxations to the three months already provided for in Rule 49 to maintain administrative consistency

Source reference: p. 6/7

The Tribunal reasoned that it cannot act as an appellate authority over the wisdom or suitability of an executive policy

Source reference: p. 8

Since the PSB's decision was taken after considering the relevant Supreme Court judgment and statutory rules, it did not suffer from non-application of mind or arbitrariness

Source reference: p. 7/10
05

Holding

The Tribunal answered both issues in the negative. It held that GDS service cannot be counted toward regular pension and that the court cannot interfere with the executive's policy decision regarding the limits of relaxation under Rule 88

The Original Application was dismissed, and the applicant was advised to seek GDS-specific gratuity benefits through a separate proceeding. No order as to costs

Source reference: p. 10
CAT - Allahabad

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RAM SUMERvsPOST UP CIRCLE

CAT - Allahabad · March 24, 2026

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