Pay stepping-up on par with juniors constitutes financial upgradation for reckoning benefits under the MACP Scheme.

The original applicant was appointed as a Sorting Assistant on October 18, 1981

He was promoted to Upper Division Clerk (UDC) on January 29, 1993, and subsequently promoted to Inspector of Posts (IP) through a Limited Departmental Competitive Examination (LDCE) on October 18, 1996

During his service, his pay was "stepped up" on par with his juniors—who received Time Bound One Promotion (TBOP) and Biennial Cadre Review (BCR) benefits—on June 26, 1993, and May 25, 1994, respectively

Upon the introduction of the Modified Assured Career Progression (MACP) Scheme on September 1, 2008, the applicant was granted MACP-III with a Grade Pay (GP) of Rs. 4,600/-

The applicant contended that he was entitled to a GP of Rs. 4,800/-, arguing that the "stepping up" of pay did not constitute financial upgradation under the MACP Scheme

The respondents later withdrew the MACP-III benefit, asserting he was ineligible for further financial upgradation

1. Whether the stepping up of pay on par with a junior’s TBOP/BCR scales constitutes a financial upgradation for the purpose of reckoning benefits under the MACP Scheme

2. Whether the applicant was entitled to a Grade Pay of Rs. 4,800/- under MACP-III from September 1, 2008

The Tribunal applied the Modified Assured Career Progression (MACP) Scheme (effective September 1, 2008), which provides for three financial upgradations at intervals of 10, 20, and 30 years of service

It relied on the precedent set in Union of India v. M.V. Mohanan Nair (2020) 5 SCC 421, which established that MACP upgradation is based on the next Grade Pay in the hierarchy, not the next promotional post

Crucially, the Tribunal applied the principle from Union of India v. N.M. Raut (2024) Supreme (SC) 1305, which held that all financial upgradations earned by an employee, including those under previous rules or different nomenclature, must be accounted for when reckoning the 10-year intervals for MACP benefits

The Tribunal examined the applicant’s service history to determine if he had already exhausted his three financial upgradations.

It noted that the applicant received two instances of "stepping up" of pay (June 1993 and May 1994) and a promotion to the IP cadre (October 1996)

However, the Tribunal, following the Supreme Court’s ruling in N.M. Raut, held that financial benefits granted on par with juniors must be accounted for as financial upgradations for the purpose of reckoning the three assured stages of the MACP Scheme

Since the applicant had already benefited from multiple pay enhancements and a promotion, the claim for a higher Grade Pay of Rs. 4,800/- under MACP-III was found to be inconsistent with the scheme’s intent to address career stagnation

The Tribunal upheld the respondents’ decision and dismissed the Original Application, finding no discrimination or illegality in denying the Grade Pay of Rs. 4,800/-

No order as to costs was made