Chhattisgarh High Court

Parity with similarly situated employees is a prerequisite for claiming benefits under service circulars.

MANORMA NATH vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: April 02, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The appellants, comprising ten individuals employed in various teaching capacities (Teachers, Assistant Teachers, and Lecturers) in District Raigarh, Chhattisgarh

Source reference: p. 1-2

filed a writ appeal challenging the order dated 24.11.2025 passed by a learned Single Judge in WP(S) No. 11785 of 2025

Source reference: para. 4

The Single Judge had dismissed their writ petition, which sought relief based on a departmental Circular dated 10.03.2017

Source reference: para. 5

The appellants claimed they were entitled to benefits as they were similarly situated to the petitioner in the case of Smt. Sona Sahu v. State of Chhattisgarh Others (WA No. 261/2023)

Source reference: para. 5

The present appeal was filed with a delay of 36 days, which the Division Bench condoned via I.A. No. 01/2026

Source reference: para. 1-2
02

Issues

1. Whether the appellants are similarly situated to the petitioner in Smt. Sona Sahu v. State of Chhattisgarh and Others (WA No. 261/2023) to qualify for benefits under the Circular dated 10.03.2017

Source reference: para. 5

2. Whether the order passed by the learned Single Judge suffered from any palpable infirmity requiring interference in an intra-court appeal

Source reference: para. 5
03

Law Applied

The court applied the doctrine of judicial precedence and the limited scope of interference in intra-court appeals.

Source reference: para. 5

It primarily relied on the judgment in Jeewan Lal Banajare and others v. State of Chhattisgarh and others (WA No. 191/2026).

Source reference: para. 5

This precedent establishes that interference in an intra-court appeal is not warranted unless "palpable infirmities" are noticed in the impugned order

Source reference: para. 5, quoting para. 32 of WA 191/2026

the court reinforced that a claim for parity with Smt. Sona Sahu (WA No. 261/2023) regarding the Circular dated 10.03.2017 is misconceived if the petitioners fail to demonstrate that they are identically situated

Source reference: para. 5, quoting para. 33 of WA 191/2026
04

Reasoning

The court noted that the legal issue involved in the present appeal was identical to the one decided in Jeewan Lal Banajare v. State of Chhattisgarh (WA No. 191/2026)

Source reference: para. 5

In that case, the Division Bench had observed that the learned Single Judge provided "cogent and justifiable reasons" for dismissing the writ petition

Source reference: para. 5, quoting para. 32 of WA 191/2026

The court emphasized that in an intra-court appeal, the appellate bench should not interfere with the findings of a Single Judge unless the decision is clearly erroneous or lacks legal foundation.

Source reference: no citation

Since the appellants in the current matter could not prove they were similarly situated to the petitioner in the Sona Sahu case, their reliance on the 2017 Circular was deemed "misconceived"

Source reference: para. 5, quoting para. 33 of WA 191/2026

Given that counsel for both parties conceded the issue was covered by the Banajare precedent, the court found no grounds to deviate from its previous findings

Source reference: para. 5-6
05

Holding

The Court condoned the 36-day delay in filing the appeal

the High Court dismissed the writ appeal, holding that the appellants failed to demonstrate they were similarly situated to the petitioner in Smt. Sona Sahu v. State of Chhattisgarh

Source reference: para. 5-6

Following the precedent set in Jeewan Lal Banajare v. State of Chhattisgarh (WA No. 191/2026), the court affirmed the Single Judge's order and declared the appellants' claims under the Circular dated 10.03.2017 to be meritless

Source reference: para. 5-6

No order was made as to costs

Source reference: para. 6
Chhattisgarh High Court

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MANORMA NATHvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · April 02, 2026

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