Similarly situated teachers must receive equivalent service benefits when parity is established.

The petitioners were appointed as Assistant Teachers in different elementary schools and were subsequently promoted as Headmasters.

They completed an in-service teachers’ training course on 30 June 2001, but their Matric Trained Pay Scale was allegedly fixed only from 1 October 2003, the date on which the training-course results were published.

Relying on the decision in Manoj Kumar & Others v. State of Bihar & Others, C.W.J.C. No. 7938 of 2020, dated 1 February 2021, which was affirmed in L.P.A. No. 456 of 2021 on 3 April 2025 and whose challenge by the State was rejected in S.L.P. (Civil) Diary No. 66035 of 2025, the petitioners sought corresponding arrears, salary fixation, and other service benefits.

They had earlier submitted representations to the District Programme Officer (Establishment), Sitamarhi, and the District Education Officer, Sitamarhi.

1. Whether the petitioners were entitled to fixation of the Matric Trained Pay Scale from 30 June 2001, the date of completion of their in-service training, instead of 1 October 2003, the date of publication of the results, in light of the precedent in Manoj Kumar?

2. Whether the competent education authorities should consider and decide the petitioners’ claim for parity, arrears, salary, and other consequential service benefits?

The Court applied the principle that similarly situated employees should receive similar service benefits where their claims are found to be at par with persons covered by an applicable judicial decision.

It relied upon the decision in Manoj Kumar & Others v. State of Bihar & Others, C.W.J.C. No. 7938 of 2020, concerning fixation of the Matric Trained Pay Scale from the date of completion of in-service training, as affirmed in L.P.A. No. 456 of 2021 and subsequently left undisturbed after the State’s challenge.

The Court further applied the administrative-law requirement that a claim must be determined by the competent authority through a reasoned and speaking order, particularly where parity with similarly situated employees is asserted.

The Court noted that the petitioners’ claim was substantially based on the judicially recognised benefit concerning the effective date of pay-scale fixation and that they asserted parity with similarly situated teachers.

However, as the factual and service particulars required examination by the competent authority, the Court did not directly grant the monetary or pay-scale benefits.

Instead, it directed the petitioners to submit a fresh representation to the Director, Primary Education.

The Director was required to examine whether the petitioners’ claims were, in principle, at par with those of the employees covered by the relied-upon precedent.

If parity was established, similar benefits were to be granted; if not, the authority was required to issue a reasoned and speaking order.

The petitioners were directed to file a fresh representation before the Director, Primary Education, preferably within four weeks.

Upon filing, the Director was directed to consider and conclude the matter preferably within a further period of ten weeks.

If the petitioners were found to be similarly situated to the beneficiaries of the relied-upon judgments, corresponding benefits were to be extended; otherwise, a reasoned and speaking order was required.