Last Pay Certificates cannot override statutory rules or government policies governing pay scale fixation.

The appellants were originally appointed as Shiksha Karmi Grade-III (Assistant Teacher, Panchayat) in 1998 and 1999.

Following eight years of service, they were absorbed into the School Education Department as Assistant Teacher (LB) effective July 1, 2018.

Under various government circulars issued between 2011 and 2013, the appellants were granted different pay scales, eventually receiving Rs. 5200–20200 with a Grade Pay (GP) of Rs. 2400 upon absorption.

The appellants contended that according to a circular dated May 17, 2013, and their Last Pay Certificate (LPC), they were entitled to a higher revised scale of Rs. 9300–34800 with a GP of Rs. 4200 from the date of absorption.

They were only granted this higher scale in October 2022 upon their promotion to the post of Head Master (Primary School).

The appellants filed a writ petition (WPS No. 3069/2023) seeking retrospective application of the higher scale from July 1, 2018, which was dismissed by the learned Single Judge on November 28, 2025.

1. Whether the appellants possessed a vested legal right to the pay scale of Rs. 9300–34800 + GP 4200 from the date of their absorption (01.07.2018) solely based on the entries in their Last Pay Certificate (LPC).

2. Whether the pay fixation by the respondent authorities was arbitrary or contrary to the governing circulars and service rules of the School Education Department.

The Court applied the principle that the grant of pay scales must strictly adhere to the eligibility criteria defined by applicable government circulars, service rules, and policy decisions.

It further established that a Last Pay Certificate (LPC) is a secondary administrative document that cannot override statutory provisions, service rules, or specific government instructions governing the fixation of pay upon departmental absorption.

The Court evaluated the appellants' claim that their absorption on July 1, 2018, should have triggered the higher pay scale mentioned in their LPC. The Court rejected this, reasoning that the appellants failed to demonstrate how they were eligible for the Rs. 9300–34800 + GP 4200 scale prior to their actual promotion.

The respondent State clarified that this specific scale only became admissible upon the appellants' promotion to the post of Head Master in October 2022.

The Court emphasized that an LPC cannot confer an enforceable right if it contradicts the underlying statutory scheme or government policy.

Furthermore, the Court found no evidence of arbitrary reduction or "downgrading" of pay; rather, the pay fixation at the time of absorption was consistent with the appellants' then-current designation as Assistant Teachers (LB).

Since the appellants could not establish a legal entitlement to the higher grade pay for the period between absorption and promotion, the Court found no error in the Single Judge’s refusal to interfere.

The Court held that the appellants were not entitled to the pay scale of Rs. 9300–34800 with Grade Pay of Rs. 4200 from the date of their absorption, as the said scale was only applicable from the date of their promotion to Head Master in October 2022.

The Court concluded that the LPC does not create an enforceable right contrary to governing rules and that the appellants failed to prove any illegality or perversity in the State's decision-making process.

No costs were ordered.