NEIGRIHMS lacks authority to alter faculty pay scales without Ministry approval.

The applicant was appointed as a Lecturer in the Nursing College of NEIGRIHMS on 1 March 2005 in the pay scale of ₹8,000–13,500.

She claimed that she subsequently joined the sanctioned post of Reader/Associate Professor on 8 August 2006, but was paid Grade Pay of ₹6,600 instead of ₹7,600.

The applicant challenged the respondents’ communications dated 9 September 2016, 24 August 2023 and 13 September 2023, as well as the Ministry’s 2023 Recruitment Amendment Rules, insofar as they merged the posts of Lecturer and Reader/Associate Professor into a single post of Associate Professor carrying the same pay level.

She also challenged the redesignation of Respondents 3 and 4 as Associate Professors and sought arrears and consequential benefits based on Grade Pay of ₹7,600 from 8 August 2006.

The respondents relied on the Ministry’s control over pay fixation and stated that proposals for pay parity with AIIMS and other institutions had not been approved by the Ministry.

The Tribunal considered its earlier decision dated 17 July 2026 in O.A. No. 327/2019, which dealt with the Ministry’s authority over implementation of service and promotion benefits at NEIGRIHMS.

Whether the merger of the posts of Lecturer and Reader/Associate Professor as a single post of Associate Professor under the 2023 Recruitment Amendment Rules was unlawful, ultra vires or liable to be quashed.

Whether the applicant was entitled to Grade Pay of ₹7,600, instead of ₹6,600, in the post of Reader/Associate Professor with effect from 8 August 2006, together with arrears and consequential benefits.

Whether the redesignation of Respondents 3 and 4 as Associate Professors pursuant to the amended Rules was liable to be set aside.

The Tribunal applied the principle that NEIGRIHMS could not independently implement or alter service benefits, pay scales or promotion-related schemes without the approval of the Ministry of Health and Family Welfare.

It relied on its earlier decision in Dr. A. B. Khyriem & Ors. v. NEIGRIHMS, O.A. No. 327/2019, where it held that the Institute lacked authority to grant benefits contrary to the Ministry’s decision and that the Ministry’s refusal to approve the Governing Council’s proposal was controlling.

The Tribunal also treated the Ministry of Health and Family Welfare, NEIGRIHMS Nursing Teaching Faculty Posts (Group ‘A’) Recruitment Amendment Rules, 2023 as the governing service framework for the disputed merger and redesignation.

No independent statutory or constitutional doctrine was elaborately applied beyond this requirement of prior Ministry approval and adherence to the applicable Recruitment Rules.

The applicant’s case was founded on the distinction between the Lecturer/Assistant Professor post carrying Grade Pay of ₹6,600 and the higher Reader/Associate Professor post carrying Grade Pay of ₹7,600.

She relied on pay structures in other nursing institutions and earlier proceedings concerning payment of Grade Pay of ₹6,600 to NEIGRIHMS Lecturers.

However, the Tribunal did not undertake a separate comparative assessment of the qualifications, duties or historical pay scales of the disputed posts.

Instead, it found the controversy substantially similar to the issue decided in O.A. No. 327/2019.

Applying the principle that the Institute’s service and pay decisions required Ministry approval, and noting that the Ministry had not accepted proposals concerning enhanced or equivalent benefits, the Tribunal declined to interfere with the impugned arrangements.

The Tribunal therefore treated the applicant’s challenge to the merger, redesignation and higher Grade Pay as lacking sufficient merit.

It declined to quash the impugned communications or the 2023 Recruitment Amendment Rules, refused to invalidate the redesignation of Respondents 3 and 4, and denied the applicant Grade Pay of ₹7,600 from 8 August 2006 with consequential benefits.

The Original Application was dismissed, with no order as to costs.