CAT - Chennai

Judicial interference in pay scale fixation is impermissible as it remains an exclusive expert executive function.

C ARUNACHALAM vs M/o Home Affairs

CAT - ChennaiJUDGMENT: March 19, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, a retired Port Conservator from the Port Department, Puducherry, served for 33 years after initially being appointed as a Morse Signaller

Source reference: para. 2

He alleged that during the 5th Central Pay Commission (CPC), he was erroneously placed in the pay scale of Rs. 4000–6000 instead of Rs. 5000–8000, despite a degree qualification being prescribed for the post

Source reference: para. 2

This perceived error was carried forward into the 6th CPC, where he was granted a Grade Pay (GP) of Rs. 2400 instead of the sought GP of Rs. 4200

Source reference: para. 2

The applicant claimed pay parity based on the technical nature of his duties, statutory functions under the Minor Ports Act, and the pay scales of similar posts in other states

Source reference: para. 3-4

The respondents countered that the Port Conservator is a supervisory role assisting the Port Officer (a Group A Gazetted post) and that a degree qualification alone does not justify a higher pay scale

Source reference: para. 6-7
02

Issues

1. Whether the applicant is entitled to a retrospective revision of the pay scale to Rs. 5000–8000 w.e.f. 01.01.1996 and a subsequent Grade Pay of Rs. 4200 w.e.f. 01.01.2006 based on the principle of "Equal Pay for Equal Work" and educational qualifications.

Source reference: para. 1 / 14

2. Whether the Tribunal can interfere with the pay structure and job evaluation determined by expert administrative bodies and Pay Commissions.

Source reference: para. 12-13
03

Law Applied

pay fixation and job evaluation are complex executive functions best left to expert bodies like Pay Commissions

Source reference: para. 12

courts should not interfere with the findings of expert committees unless they are based on extraneous considerations (Punjab State Power Corporation Ltd. vs. Rajesh Kumar Jindal (2019))

Source reference: para. 13

doctrine of "Equal Pay for Equal Work" requires a "complete and wholesale identity" between groups, and mere similarity in work nature or educational qualifications is insufficient to claim parity (S.C. Chandra v. State of Jharkhand (2007) and Steel Authority of India Limited v. Dibyendu Bhattacharya (2011))

Source reference: para. 13
04

Reasoning

The Tribunal reasoned that the determination of pay scales involves evaluating the nature, quality, and quantum of work, which is the prerogative of the Executive

Source reference: para. 12

The court noted that the respondents had distinguished the duties of a Port Conservator from those of a Port Officer, the latter being a statutory authority with higher responsibilities

Source reference: para. 6-8

The Tribunal observed that the Puducherry Pay Anomaly Committee (PPAC) had already considered the applicant's claim and determined that a degree requirement alone was not a sufficient criterion for a higher scale

Source reference: para. 7

Applying the cited precedents, the Tribunal found that the applicant failed to prove a "wholesale identity" between his post and the higher-paid positions

Source reference: para. 13

Consequently, it held that judicial restraint was necessary to avoid a cascading effect on the government’s financial and administrative structure

Source reference: para. 12-13
05

Holding

The Tribunal dismissed the Original Application, holding that it could not grant pay parity or intervene in the pay structure, especially since the 7th CPC recommendations had already been implemented

The court found the applicant’s claims regarding retrospective pay fixation to be devoid of merit and declined to issue any directions to the respondents

Source reference: para. 14-15

No order as to costs was made

Source reference: para. 15
CAT - Chennai

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C ARUNACHALAMvsM/o Home Affairs

CAT - Chennai · March 19, 2026

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