Recovery of mistakenly paid increments is impermissible from Group C employees, regardless of the overpayment period.

The applicants, Group C Postmen, received periodical increments despite not initially producing the driving licences required under Notes 2 and 3 of the Department of Posts Postman and Mail Guard (Group ‘C’ Post) Recruitment (Amendment) Rules, 2020.

After the applicants later obtained and submitted their licences, the respondents began monthly salary deductions in September 2025 to recover the increments, without issuing a recovery order or show-cause notice. The applicants sought to quash the deductions and recover the amounts already withheld.

The respondents maintained that the increments had been paid inadvertently and that recovery was permissible under the applicable financial rules.

Whether the respondents could recover mistaken excess increment payments from the applicants’ salaries when they were Group C employees.

Whether the deductions could be sustained when they were made without prior notice, a recovery order, or an opportunity to be heard.

Under paragraph 12(i) of State of Punjab v. Rafiq Masih (White Washer), (2015) 4 SCC 334, recovery of mistaken excess payments from Group C and Group D employees is impermissible; this protection is distinct from the separate five-year limitation in paragraph 12(iii).

The Tribunal relied on Chaturbhuj Rathore v. Union of India and Maha Nagar Telephone Nigam Ltd. v. Shri Ramdhan Gupta, 2019 SCC OnLine Del 7125, for the proposition that the categories in Rafiq Masih are independent.

It also applied the principles of natural justice, requiring procedural fairness before administrative action causing civil and financial consequences.

The applicants were undisputedly Group C employees, and the increments had been sanctioned and paid by the respondents without any false declaration, fraud, or inducement by the applicants.

The Tribunal therefore applied the Group C protection in Rafiq Masih independently of the five-year category; the respondents’ argument that the overpayment covered less than five years did not alter the result.

The deductions were also procedurally deficient because they had been made without prior notice, an order, or a hearing.

It directed the respondents to stop further deductions and refund or re-credit the amounts already recovered within two months of receiving a certified copy of the order. No costs were awarded.