Supreme Court judgment in M. Siddaraj is a judgment in rem applicable to State Government employees.

The petitioner, a retired Stenographer from the Revenue Department, superannuated on 30/06/2021

He sought the benefit of an annual increment due on 01/07/2021. Following a previous writ petition and a subsequent contempt petition, the respondents issued a revised Pension Payment Order (PPO) and paid arrears

However, the petitioner filed a representation seeking further benefits/adjustments based on the Supreme Court’s clarification in Union of India v. M. Siddaraj. The respondent authority rejected this representation via order dated 10/04/2026 (Annexure P/1), asserting that the M. Siddaraj judgment applied only to Central Government employees and not to the State of Madhya Pradesh

1. Whether the directions issued by the Hon'ble Supreme Court in Union of India v. M. Siddaraj regarding the grant of annual increments to retired employees are judgments in rem applicable to State Government employees

2. Whether the respondent’s rejection of the petitioner’s representation on the grounds of the judgment's non-applicability was legally sustainable

The Court applied the legal principles established by the Supreme Court in Director (Admn. and HR) KPTCL & Ors v. C.P. Mundinamani & Ors., which entitled employees retiring a day before the increment date to that benefit

It further relied on the procedural and temporal clarifications regarding arrears and effective dates set out in Union of India & Anr. v. M. Siddaraj (Misc. Application Diary No. 2400 of 2024 in Civil Appeal No. 3933 of 2023), specifically Clauses (a) through (d) of the order dated 06.09.2024 and the final order dated 20.02.2025

The Court also invoked the doctrine of judgment in rem, which implies the ruling applies to all similarly situated persons regardless of whether they were parties to the original suit

The High Court observed that the State Government’s approach in dismissing the petitioner’s representation was "casual". The Court reasoned that the Supreme Court’s decision in M. Siddaraj was not a judgment in personam (restricted to the specific parties) but a judgment in rem, meaning its interpretation of entitlement to increments and the calculation of periodic arrears carries universal applicability to all civil servants under the Union and States

The Court analyzed the modified Clause (d) of the M. Siddaraj order, noting it provides for enhanced pension including one increment for a period of three years prior to the filing of the petition/application. Consequently, the State's contention that the ruling did not apply to its employees was found to be legally erroneous

The petition was disposed of with a direction to the petitioner to file a fresh representation. The respondents are directed to decide the representation by passing a speaking order in light of the M. Siddaraj judgment within three months of receipt