Jharkhand High Court

Parity in pay scale benefits must be granted when the denial of retrospective parity lacks a rational basis.

DR MRITUNJAY KUMAR vs THE STATE OF JHARKHAND

Jharkhand High CourtJUDGMENT: June 22, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

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. 3

Following 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. 3

However, 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. 4

The 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. 4

Following a court remand in 2018, the respondents issued a fresh rejection on 04.06.2021, leading to the current writ petition

Source reference: p. 5
02

Issues

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. 7-8

2. 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. 8-9
03

Law 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. 11

It 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. 8

The 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. 9-10
04

Reasoning

The Court found the State's distinction between the petitioners and the Lady Extension Officers to be "misconceived and irrelevant"

Source reference: p. 8

Upon 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. 9-10

Since 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. 10

Consequently, the differential treatment in the effective date of the pay scale lacked a rational basis and violated the principle of parity

Source reference: p. 11
05

Holding

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. 11

The 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. 11

The State was further ordered to release all consequential benefits and arrears of salary within sixteen weeks

Source reference: p. 11
Jharkhand High Court

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DR MRITUNJAY KUMARvsTHE STATE OF JHARKHAND

Jharkhand High Court · June 22, 2026

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