CAT - Delhi

Statutory 300-day leave encashment cap includes prior payments and prevails over conflicting executive instructions.

SUNIL ARORA vs National Human Rights Commission (NHRC)

CAT - DelhiJUDGMENT: April 07, 20263 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicants were employees of the National Human Rights Commission (NHRC) who had previously served in various Central Government departments before being permanently absorbed into the NHRC

Source reference: p. 5-6

Upon their initial absorption, they received leave encashment for the service rendered in their parent departments (e.g., the lead applicant received 234 days)

Source reference: p. 13

Upon retirement from the NHRC, the respondent capped their final leave encashment such that the total days encashed across their entire career did not exceed 300 days

Source reference: p. 13-14

The applicants challenged this, seeking a full 300 days of leave encashment for their service post-absorption, relying on a DoPT Office Memorandum (OM) dated 25.03.2013 which stated that prior encashment should not be taken into account

Source reference: p. 7

The NHRC had briefly followed this practice but reverted to the 300-day cap in 2019 following an audit objection and subsequent clarifications from the Ministry of Home Affairs (MHA)

Source reference: p. 13-14, 21-23
02

Issues

1. Whether the total leave encashment admissible to an employee absorbed into the NHRC is subject to a cumulative ceiling of 300 days for their entire service career, or if they are entitled to a fresh 300 days post-absorption

Source reference: p. 3-4, 18-19

2. Whether executive instructions/FAQs issued by the DoPT can override statutory service rules regarding leave encashment limits

Source reference: p. 23-24
03

Law Applied

Rules 3 and 4 of the National Human Rights Commission (Conditions of Service of Officers and Staff) Rules, 2000, which mandate that service conditions, including leave and retirement benefits, shall be regulated by rules applicable to Central Government employees

Source reference: p. 17-18

Rule 39 of the CCS (Leave) Rules, 1972, was applied, which stipulates a maximum overall limit of 300 days for leave encashment

Source reference: p. 18, 24

The principle from Dr. Dudh Nath Pandey v. State of Jharkhand, which establishes that executive instructions cannot override statutory rules

Source reference: p. 23-24

State of Sikkim Ors. v. Dr. Mool Raj Kothari, affirming that leave encashment is a reward for work ethic but must not lead to unjust enrichment beyond the statutory cap

Source reference: p. 11-13
04

Reasoning

The Tribunal reasoned that the NHRC is a statutory body governed by the Protection of Human Rights Act, 1993, and its own 2000 Service Rules

Source reference: p. 17, 19

Rule 4 of the NHRC Rules explicitly incorporates the CCS (Leave) Rules, 1972, by reference

Source reference: p. 18

Rule 39 of the CCS (Leave) Rules clearly sets a ceiling of 300 days for the "entire service career"

Source reference: p. 24-25

The Tribunal observed that while the DoPT OM of 2013 suggested a fresh 300-day limit post-absorption, this was merely an executive instruction/FAQ; such an instruction cannot supersede the statutory cap provided under Rule 39 of the CCS Rules as integrated by the NHRC’s own statutory rules

Source reference: p. 19-20, 24

The Tribunal further noted that even for high-ranking officials like the Chairperson and Members of the NHRC, specific notifications restricted total encashment to 300 days, making the applicants' claim for "300 + 300" days logically inconsistent with the broader regulatory framework

Source reference: p. 22
05

Holding

The Tribunal dismissed the Original Applications, holding that the applicants are not entitled to leave encashment beyond the cumulative limit of 300 days

The court affirmed that the calculation of the 300-day limit must include any leave encashment already availed by the employee from their parent department prior to absorption

Source reference: p. 25

No order was made as to costs

Source reference: p. 25
CAT - Delhi

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SUNIL ARORAvsNational Human Rights Commission (NHRC)

CAT - Delhi · April 07, 2026

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