Facts
The petitioners are officers of the Jharkhand Animal Husbandry Service appointed in 1994 by the Bihar Public Service Commission and later allotted to the Jharkhand cadre
Source reference: p. 3Following the 5th Pay Revision, the State granted them a pay scale of Rs. 8,000–13,500 effective from 15.11.2000
Source reference: p. 3However, the State granted other categories of employees, such as Lady Extension Officers and certain Lecturers, the same benefits notionally from 01.01.1996 and actually from 01.04.1997
Source reference: p. 4The petitioners’ previous representations were rejected on the grounds that the comparison group received benefits via a Fitment Appellate Committee recommendation, whereas the petitioners’ scale was a separate policy decision
Source reference: p. 4Following a court remand in 2018, the respondents issued a fresh rejection on 04.06.2021, leading to the current writ petition
Source reference: p. 5Issues
1. Whether the denial of actual monetary benefits of the revised pay scale to the petitioners from 01.04.1997, while granting the same to similarly situated employees of other departments, constitutes an arbitrary and discriminatory exercise of power
Source reference: p. 7-82. Whether the respondent's justification—that the parity group’s benefits were based on a Fitment Appellate Committee report while the petitioners’ were not—is factually and legally sustainable
Source reference: p. 8-9Law Applied
The Court applied the principle of Article 14 of the Constitution of India regarding equality before the law and the prohibition of discrimination in matters of public employment
Source reference: p. 11It further examined the administrative law principle that "policy decisions" cannot be used as a tool for arbitrary classification when no substantial difference exists between the groups
Source reference: p. 8The Court scrutinized the implementation of the 5th Pay Revision (Resolution No. 660) and the specific findings of the Fitment Appellate Committee report
Source reference: p. 9-10Reasoning
The Court found the State's distinction between the petitioners and the Lady Extension Officers to be "misconceived and irrelevant"
Source reference: p. 8Upon examining the Fitment Appellate Committee report (Annexure-9), the Court observed that the Committee had not actually fixed any specific effective date for the pay scale; rather, it was the State Government that decided to improve the applicability dates for Lady Extension Officers to 01.04.1997 via a subsequent resolution
Source reference: p. 9-10Since the respondents could not provide evidence that the Committee mandated a different timeline for the comparison group, the Court determined that the only barrier cited by the State—the lack of a Committee recommendation—was factually nonexistent
Source reference: p. 10Consequently, the differential treatment in the effective date of the pay scale lacked a rational basis and violated the principle of parity
Source reference: p. 11Holding
The Court allowed the writ petition, holding that the respondents failed to justify the differential treatment given to the petitioners
The Court quashed the impugned order dated 04.06.2021
Source reference: p. 11The respondents were directed to extend the pay scale of Rs. 8,000–13,500 to the petitioners notionally from 01.01.1996 and actually from 01.04.1997
Source reference: p. 11The State was further ordered to release all consequential benefits and arrears of salary within sixteen weeks
Source reference: p. 11Original Court PDF
DR MRITUNJAY KUMARvsTHE STATE OF JHARKHAND
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