MP HC Upholds Retrospective Pay Benefits for Mandi Employees Similarly Placed to Worker Who Won Labour Court Award

The connected appeals arose from writ petitions by employees who sought service benefits equivalent to those granted to Rajendra Prasad Shrivastava, including retrospective regular-pay-scale benefits from 29 July 1998.

Shrivastava had obtained a Labour Court award in 2004, which became final after challenges were dismissed; the State Level Scrutiny Committee later recommended consequential benefits for him.

The Board opposed extending those benefits, arguing that the respondents’ regularisation orders were prospective, their claims were delayed, and the Labour Court award bound only the parties to that dispute.

The Single Judge directed that the benefit of the award be extended to the petitioners.

The Board appealed.

The judgment also records a separate appeal by Prabhulal Kushwaha, who challenged rejection of his regularisation claim, and appeals concerning promotion claims from L.D.C. to Secretary.

The appeals were heard together because they involved common issues.

Under Articles 14 and 16 of the Constitution, similarly situated employees should ordinarily be treated alike; granting relief to one group while denying it to others in the same category may amount to discrimination.

In State of U.P. v. Arvind Kumar Srivastava, (2015) 1 SCC 437, the Supreme Court stated that this rule is subject to exceptions for delay, laches and acquiescence, although those exceptions may not apply where a judgment is intended to operate in rem and benefit all similarly situated persons.

The Court also relied on State of Karnataka v. C. Lalitha, (2006) 2 SCC 747, and Amrit Lal Berry v. Collector of Central Excise, (1975) 4 SCC 714, concerning equal treatment and the obligation of public authorities to extend applicable benefits to similarly situated employees.

It referred to Secretary, State of Karnataka v. Uma Devi, (2006) 4 SCC 1, on the distinction between illegal and irregular appointments, and to Jaggo v. Union of India, (2026) 4 SCC 1, concerning the treatment of long-serving temporary employees.

The Court accepted that the writ petitioners were similar to Shrivastava and observed that the Board had denied them the benefit because Shrivastava had pursued a Labour Court remedy while they approached the High Court later.

It considered that requiring each similarly situated employee to litigate separately would burden both employees and the courts, and stressed that a public employer should extend an applicable service benefit consistently.

Although the Board relied on delay, acquiescence and the individual nature of the Labour Court award, the Court upheld the Single Judge’s direction.

The judgment does not separately analyse the factual or legal merits of the regularisation claim in W.A. No. 2163/2024 or the promotion appeals in its final reasoning.

The judgment does not state a separate operative disposition for W.A. No. 2163/2024, filed by Prabhulal Kushwaha, or separately set out the result for the distinct regularisation and promotion claims.