Judicial Review Precludes Direct Mandate for Specific Multiplier Factors in Complex Pay Scale Revisions

The respondents, supervisory cadre employees in the Tamil Nadu State Transport Corporation (TNSTC), filed writ petitions seeking a pay fixation based on a 2.57 multiplier factor as per G.O.Ms.No.134 dated 09.04.2018.

The Writ Court allowed these petitions in November 2025, directing the appellants to fix the pay using the 2.57 matrix and disburse arrears.

The appellants (TNSTC) challenged these orders, contending that the supervisory officials had already received a 5.5% pay hike under a 2013 Wage Settlement and were therefore governed by G.O.Ms.No.330 dated 31.10.2018, which prescribes a 2.44 multiplier factor rather than 2.57.

1. Whether the Writ Court was justified in issuing a direct mandate to fix the employees' pay using a 2.57 multiplier factor instead of leaving the determination to the executive/expert bodies.

2. Whether the respondents were legally entitled to the 2.57 multiplier factor under G.O.Ms.No.330, considering they had received prior pay revisions.

the "equal pay for equal work" doctrine is not abstract and its application must be determined by expert bodies rather than through mechanical judicial interference (State of Bihar v. Bihar Secondary Teachers Struggle Committee).

granting pay scales is a purely executive function (S.C. Chandra v. State of Jharkhand).

courts should only interfere if a government pay decision is "patently irrational, unjust, and prejudicial," and even then, the matter should generally be remanded to the government for reconsideration rather than the court declaring a specific scale (State of Haryana v. Haryana Civil Secretariat Personal Staff Association).

The Court analyzed the specific guidelines in G.O.Ms.No.330 dated 31.10.2018, noting that Clause (vi) explicitly restricts the 2.57 multiplier factor to employees who did not receive any pay revision between 2006 and 2016.

Since the respondents had already enjoyed a 5.5% hike in the 2013 Wage Settlement, the Court reasoned that applying a 2.57 factor would be unreasonable and inconsistent with the government's policy, which prescribed a 2.44 factor for this category.

The Court found that the Writ Court had erroneously interpreted the Government Orders and bypassed the executive's role in complex pay equations.

It determined that a straight judicial direction for a specific multiplier creates an undue financial burden on the exchequer and exceeds the scope of judicial review.

the 2.57 multiplier factor is not a default entitlement for all supervisory officials.

The High Court allowed the writ appeals and set aside the impugned orders of the Writ Court. No costs were awarded.