CAT - ['Delhi']

Financial Upgradations under ACP/MACP Cannot Be Retrospectively Denied if No Judicial Proceedings Were Pending on Eligibility Date

Atanu Sinha vs M/o Power

CAT - ['Delhi']JUDGMENT: May 07, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant joined the National Power Training Institute (NPTI) as a Graphic Artist (an isolated post) on 29.11.1982

Source reference: p. 2

He was granted the 1st financial upgradation under the ACP Scheme effective 09.08.1999

Source reference: p. 8, para. 14.1

An FIR was registered against him by the CBI on 28.01.2003 regarding forged undertakings for a bank loan

Source reference: p. 2-3

The CBI filed a charge sheet on 05.08.2009, and the Trial Court took cognizance on 28.08.2009

Source reference: p. 7, 11

On 26.08.2011, he was convicted under Sections 420, 471, and 468 of the IPC but was released on probation

Source reference: p. 3, 16

He superannuated on 31.12.2014, the same day a departmental penalty of "Censure" was imposed

Source reference: p. 4, 15-16

The applicant approached the Tribunal seeking the 2nd and 3rd financial upgradations under ACP/MACP schemes, which the respondents had withheld due to the criminal proceedings

Source reference: p. 5, 12
02

Issues

1. Whether the applicant was entitled to the 2nd financial upgradation under the ACP scheme on the date he completed 24 years of service

Source reference: p. 12, para. 14.3

2. Whether the pendency of a criminal investigation (prior to cognizance) or a subsequent conviction with release on probation bars the grant of financial upgradations

Source reference: p. 13-14

3. Whether the applicant was entitled to the 3rd financial upgradation under the MACP scheme

Source reference: p. 16, para. 18
03

Law Applied

The court applied the ACP and MACP Schemes governing financial upgradations for employees in stagnated posts

Source reference: p. 2

It relied on Section 2(i) of the Code of Criminal Procedure, 1973, to define "judicial proceedings"

Source reference: p. 13

The court followed the established principle that judicial proceedings commence only when a court takes cognizance of an offense

Source reference: p. 14

While an order of release on probation under the Probation of Offenders Act may substitute a sentence, it does not erase the fact of conviction or the attendant stigma for the purpose of service benefits

Source reference: p. 15, para. 17
04

Reasoning

The Tribunal found that the applicant completed 24 years of service on 29.11.2006, making him eligible for the 2nd ACP

Source reference: p. 12

The CBI only filed the charge sheet in 2009, and the Trial Court took cognizance on 28.08.2009; therefore, no "judicial proceedings" were pending as of the 2006 eligibility date

Source reference: p. 14, para. 14.6; p. 15

No departmental proceedings were pending in 2006, as the charge memo was only issued in 2014

Source reference: p. 13, para. 14.4

Regarding the 3rd MACP (due on 29.11.2012), the Tribunal noted the applicant had been convicted by the Trial Court on 26.08.2011

Source reference: p. 16

Although he was released on probation, the conviction remained a matter of record and a valid ground for denial of the 3rd upgradation

Source reference: p. 16, para. 18-19
05

Holding

The applicant is entitled to the 2nd financial upgradation under the ACP scheme w.e.f. 29.11.2006 because no proceedings were legally pending on that date

The claim for the 3rd MACP was denied due to the applicant's prior conviction in 2011

Source reference: p. 16, para. 19

The OA was partially allowed. The respondents were directed to grant the 2nd ACP, revise the pension and pensionary benefits, and issue a revised PPO within eight weeks

Source reference: p. 17, para. 20
CAT - ['Delhi']

Original Court PDF

Atanu SinhavsM/o Power

CAT - ['Delhi'] · May 07, 2026

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