Pay stepping-up claims must be decided under prescribed guidelines, not directly ordered by courts.

The respondent sought stepping up of her pay on par with her junior, who was allegedly receiving a higher salary after being promoted as Headmistress upon obtaining Selection Grade.

The writ Court, relying on G.O.Ms.No.25, Personnel and Administrative Reforms (FR.IV) Department, dated 23.03.2015, directed the authorities to step up the respondent’s pay.

The State authorities challenged that order in the present writ appeal.

During the pendency of the matter, the Government issued G.O.Ms.No.164, School Education Department, dated 16.07.2025, prescribing guidelines for considering claims relating to stepping up of pay, pursuant to the recommendations of the One Man Commission.

Whether the High Court could directly direct stepping up of the respondent’s pay merely by comparing her salary with that of her junior and relying on G.O.Ms.No.25 dated 23.03.2015?

Whether the respondent’s claim for stepping up of pay was required to be reconsidered by the competent authorities in accordance with G.O.Ms.No.164, School Education Department, dated 16.07.2025?

Stepping up, fixation, or refixation of pay involves examination of the employee’s complete service records and is ordinarily an executive and expert determination.

A higher salary drawn by a junior does not, by itself, establish entitlement to stepping up, particularly where the difference may arise from incentive increments or other benefits granted for additional qualifications.

Relying on State of Bihar v. Bihar Secondary Teachers Struggle Committee, AIR 2019 SC 2521, and S.C. Chandra v. State of Jharkhand, (2007) 8 SCC 279, the Court held that pay-scale and salary-equation matters should generally be left to the executive authorities and that courts should exercise judicial restraint.

Under State of Haryana v. Haryana Civil Secretariat Personal Staff Association, (2002) 6 SCC 72, judicial review is warranted only where the Government’s decision is patently irrational, unjust, or prejudicial, and even then the normal remedy is reconsideration by the authority rather than a direct declaration of entitlement to a particular pay scale.

Claims in the Education Department were required to be considered in accordance with the guidelines issued under G.O.Ms.No.164 dated 16.07.2025.

The Court held that the writ Court had granted the relief without adequately determining the basis on which the junior received the higher salary.

The junior’s additional remuneration could have resulted from an incentive increment, Selection Grade, additional qualification, or another service-related benefit; therefore, a mere senior-junior comparison was insufficient to establish an entitlement to stepping up.

Since pay fixation requires verification of the entire service record and involves financial and administrative considerations, the High Court ought not to have directly ordered stepping up of pay.

The subsequent issuance of G.O.Ms.No.164 provided the applicable framework for examining such claims, making it appropriate to set aside the earlier writ direction and require the competent authorities to reconsider the respondent’s claim under the new guidelines.

The order dated 05.03.2024 in W.P.No.5438 of 2024 directing stepping up of the respondent’s pay was set aside.

The appellants were directed to consider the respondent’s claim in accordance with G.O.Ms.No.164, School Education Department, dated 16.07.2025, as expeditiously as possible.

No costs were awarded, and the connected miscellaneous petition was closed.