CAT - ['Chandigarh']

Service in Grade Pay 4800 qualifies for non-functional Grade Pay 5400 after four years, regardless of mode of entry.

VED PARKASH SHARMA vs DEPTT OF POSTS

CAT - ['Chandigarh']JUDGMENT: April 23, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicants (retired and serving Group-B officials of the Department of Posts) filed this Original Application seeking the grant of Grade Pay (GP) of Rs. 5400 in Pay Band-2 (PB-2) on a non-functional basis

Source reference: p. 2

They contended that they were entitled to this upgrade upon completing four years of regular service in the Grade Pay of Rs. 4800, irrespective of whether that grade was reached via promotion or through the MACP Scheme

Source reference: p. 3, para. 4

The applicants challenged an impugned letter dated 19.06.2023 (Annexure A-6) which restricted these benefits only to specific litigants in previous cases

Source reference: p. 2

Applicant No. 4 withdrew his claim during the proceedings as he was deemed ineligible

Source reference: p. 3, para. 3
02

Issues

1. Whether the applicants are entitled to the Non-Functional Selection Grade (NFSG) in the Grade Pay of Rs. 5400 after four years of service in GP Rs. 4800, even if the latter was obtained via MACP

Source reference: p. 2-3, para. 2 & 4

2. Whether the benefits of a settled legal position can be restricted only to the original litigants or members of a specific association

Source reference: p. 3, para. 27
03

Law Applied

The Tribunal applied the provisions of Part-C, Section II of the 1st Schedule of the CCS (Revised Pay) Rules, 2008, and Rule 13(i) regarding pay fixation

Source reference: p. 2

It relied heavily on the principle of in rem judgments for similarly situated employees as established by the Hon’ble Supreme Court in Lalita S. Rao and Lt. Col. Suprita Chandel, which mandate that benefits flowing from a settled legal position must be extended to all eligible employees regardless of their participation in prior litigation

Source reference: p. 3, para. 27

The Tribunal further followed the precedents set in M. Subramanian (upheld by the Supreme Court in SLP(C) No. 15627/2011) and Surinder Pal Sharma & Ors. v. Union of India (OA No. 951/2023)

Source reference: p. 2-3
04

Reasoning

The Tribunal examined the case in light of its recent decision in Surinder Pal Sharma (2025), noting that the facts and respondents were identical

Source reference: p. 2, para. 2

The court reasoned that the nature of the Grade Pay (whether obtained through substantive promotion or MACP) is irrelevant for the purpose of granting the non-functional upgrade to Rs. 5400, provided the four-year residency requirement in GP Rs. 4800 is met

Source reference: p. 3, para. 26

The Tribunal rejected the respondents' restrictive interpretation of the impugned letter (Annexure A-6), qualifying it as "unsustainable in law" because it discriminated against similarly situated employees who were not parties to the earlier litigation

Source reference: p. 3, para. 27

By aligning this case with the settled ratio in M. Subramanian, the Tribunal ensured consistency in the application of the CCS (RP) Rules

Source reference: p. 4, para. 5
05

Holding

The Tribunal allowed the OA for Applicants 1, 2, and 3, while dismissing it for Applicant 4 as not pressed

It quashed the impugned order dated 19.06.2023 to the extent it denied benefits to the applicants

Source reference: p. 4, para. 5

The respondents were directed to grant the Grade Pay of Rs. 5400 (Level-9) effective from the date each applicant completed four years in GP Rs. 4800, including pay fixation, one additional increment, and arrears with interest at the GPF rate, within three months

Source reference: p. 4, para. 5
CAT - ['Chandigarh']

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VED PARKASH SHARMAvsDEPTT OF POSTS

CAT - ['Chandigarh'] · April 23, 2026

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