CAT - Delhi

Headline: Delayed retirement benefits attract interest at GPF rate, compounded for all applicable dues.

Sahensar Pal v. MCD & Anr., O.A. No.3928/2023

CAT - DelhiJUDGMENT: no citation2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, Sahensar Pal, a retired Mali of MCD, aged 62 years, filed an Original Application seeking the release of various pension-cum-retirement benefits, including Gratuity and Commuted Pension benefits, 7th CPC benefits, MACP Scheme benefits, DA Arrears, Bonus, Non-matric allowance, and Uniform Allowance, along with annually compounded interest at 12%

Source reference: p.2

The respondents, MCD, acknowledged that while Leave Encashment (Rs. 5,33,320), GIS (Rs. 10,060), and GPF (Rs. 8,54,623) had been paid, Retirement Gratuity (Rs. 8,53,312) and Commutation Pension (Rs. 7,82,671) were still unpaid.

Source reference: p.2-3

The delay was attributed to a financial crisis in the Municipal Corporation of Delhi

Source reference: p.2-3
02

Issues

1. Whether the respondents should be directed to release all pending pension-cum-retirement benefits to the applicant, including Gratuity and Commuted Pension benefits

Source reference: p.2

2. Whether the applicant is entitled to 7th CPC benefits, MACP Scheme benefits, DA Arrears, Bonus, Non-matric allowance, and Uniform Allowance

Source reference: p.2

3. Whether the applicant is entitled to interest at 12% annually compounded on the delayed payment of pension-cum-retirement and other benefits

Source reference: p.2
03

Law Applied

The Tribunal applied the principle established in `O.A. No. 2821/2023, Rajbir Singh vs. MCD & Ors.`, decided on 30.10.2025, which held that interest is payable on delayed payment of GPF, pension, and gratuity at the GPF rate for the relevant years, calculated on a compound interest basis

Source reference: p.3-4

This precedent clarified that such interest is mandated by Rule 65 (though not explicitly stated which Rule 65) and distinguished service matters from contractual agreements in cases like `D. Khosla and Company vs. Union of India`

Source reference: p.4

The Tribunal also noted that the due date for grant of interest is the date of superannuation, as it is a well-settled legal principle

Source reference: p.4
04

Reasoning

The court noted that the respondents' status report confirmed the non-payment of Retirement Gratuity and Commutation Pension to the applicant, acknowledging the delay due to financial constraints

Source reference: p.3

The applicant's counsel referred to the decision in `Rajbir Singh vs. MCD & Ors.`, which explicitly mandates interest on delayed payment of GPF, pension, and gratuity, calculated on a compound interest basis at the GPF rate

Source reference: p.3-4

The Tribunal found this precedent directly applicable, deeming the due date for such interest to be the date of superannuation

Source reference: p.4

This application effectively addressed the applicant's prayer for interest and upheld the principle of timely disbursement of retirement benefits

Source reference: p.2, p.4
05

Holding

The O.A. was disposed of, directing the respondents to release all admissible payments, if not already released, within two months from the date of receipt of the certified copy of the Order

The applicant was held entitled to interest in terms of the decision in `O.A. No. 2821/2023, Rajbir Singh (supra)`, subject to the final outcome of proceedings pending before the Hon'ble High Court of Delhi in that matter

Source reference: p.4-5

There was no order as to costs

Source reference: p.5
CAT - Delhi

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Sahensar Pal v. MCD & Anr., O.A. No.3928/2023

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