Patna High Court

Statutory Grievance Redressal Rules Constitute an Alternative Remedy for Service Benefits and MACP Disputes

MazharAlam @ Md. MazharAlam vs The State of Bihar

Patna High CourtJUDGMENT: July 16, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, a Lower Division Clerk (LDC) in the Registry Office, Aurangabad, filed this writ petition seeking a Writ of Mandamus to direct the respondents (specifically Respondent No. 5) to grant him the benefits of the first ACP/MACP with a Grade Pay of Rs. 2000/- effective from July 1, 2014

Source reference: p. 1-2

He further sought the payment of consequential arrears with interest, asserting parity with similarly situated LDCs in the State

Source reference: p. 2

During the hearing, the State raised a preliminary objection regarding the maintainability of the petition, citing the existence of an alternative statutory remedy for grievance redressal

Source reference: p. 2-3
02

Issues

1. Whether the petitioner’s claim for service benefits (ACP/MACP) must first be adjudicated under the Bihar Government Servant Grievance Redressal Rules, 2019

Source reference: p. 3

2. Whether the writ petition can be entertained directly despite the availability of an alternative administrative remedy

Source reference: p. 5
03

Law Applied

The Court applied the Bihar Government Servant Grievance Redressal Rules, 2019. Specifically, Rule 2(c) defines a "Complaint" to include all matters relating to service benefits such as appointments, salary increments, and Promotions/ACP/MACP

Source reference: p. 3

Rule 3 prescribes the mandatory procedure for filing such complaints online by serving or retired employees

Source reference: p. 4
04

Reasoning

The Court analyzed the definition of "Complaint" under Rule 2(c) of the 2019 Rules and noted that the petitioner’s specific relief—the grant of ACP/MACP—falls squarely within the ambit of the grievance redressal mechanism established by the State

Source reference: para 4

The Court observed that the Rules of 2019 were specifically framed by the General Administration Department to handle such service-related disputes

Source reference: para 3

Consequently, rather than adjudicating the merits of the grade pay claim, the Court found it appropriate to redirect the petitioner to the statutory authority, as the rules provide a time-bound and formal procedure for such resolutions

Source reference: para 5
05

Holding

The Court did not rule on the merits of the ACP/MACP claim but disposed of the writ petition by directing the petitioner to avail himself of the alternative remedy under the 2019 Rules

The petitioner was granted 30 days to file a formal complaint before the concerned authority, and the authority was directed to decide the matter strictly within the timeframe specified in the Rules of 2019

Source reference: para 5
Patna High Court

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MazharAlam @ Md. MazharAlamvsThe State of Bihar

Patna High Court · July 16, 2026

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