Non-Compounded Advance Increments Denied for PhD Pursued Without Prior Permission and in Irrelevant Discipline

The Petitioner joined the Indian Council for Agricultural Research (ICAR) as a Scientist S-1 in 1986.

In 1999, he registered for a Ph.D. in Social Science at Magadh University regarding "Food in Ancient India".

Although the Petitioner claimed he applied for permission, the ICAR did not respond; he proceeded with the course without formal authorization.

Following an ICAR incentive scheme effective from September 1, 2008, which granted three advance increments for acquiring a Ph.D. in a "relevant discipline," the Petitioner applied for the benefit.

The ICAR rejected the application, citing a lack of prior permission and asserting the degree was not in a relevant discipline.

The Petitioner's challenge before the Central Administrative Tribunal (OA 1115/2015) was dismissed on May 13, 2019.

1. Whether the Petitioner was entitled to three advance increments under the ICAR incentive scheme despite lacking prior permission and completing a Ph.D. in a discipline deemed irrelevant by the employer.

2. Whether the subject of the Petitioner's Ph.D. ("Food in Ancient India - As depicted in literature") qualifies as a "relevant discipline" under the ICAR policy.

The court applied the specific Ph.D. incentive policy of the ICAR effective from 01.09.2008, which mandates that three non-compounded advance increments are granted only if a Scientist acquires a Ph.D. from a university following the registration, course-work, and external evaluation processes "as prescribed by the ICAR" and in a "relevant discipline".

The court also applied the principle of limited judicial review under certiorari jurisdiction, noting that courts typically should not substitute their subjective judgment for an employer's determination on the "relevance" of a technical or academic discipline to its organizational activities.

The Court observed that the Petitioner failed to meet the strict criteria of the ICAR scheme.

Specifically, the Petitioner did not follow the evaluation and registration process "as prescribed by the ICAR" because he embarked on the course without obtaining prior permission.

The Court further reasoned that by bypassing the permission process, the Petitioner deprived the ICAR of the opportunity to evaluate the relevance of the study beforehand.

Regarding the subject matter ("Food in Ancient India... from prehistory to C 75 A.D."), the Court held that the ICAR’s decision—that such a topic was not relevant to its contemporary agricultural activities—was not arbitrary.

Consequently, the Court found no grounds to interfere with the Tribunal's decision.

The ICAR did not act arbitrarily in determining the Ph.D. was irrelevant, and the Petitioner's failure to follow prescribed administrative procedures (obtaining permission) disqualified him from the benefit.

The Writ Petition was dismissed with no orders as to costs.