Patna High Court

Teachers are entitled to trained pay scale benefits from the date of completion of training.

Vikram Mishra vs The State of Bihar

Patna High CourtJUDGMENT: July 24, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The thirty-one petitioners were appointed as untrained Panchayat, Prakhand, or Nagar Teachers between 2013 and 2016.

Source reference: para. 2

Though they completed their training in various sessions, the final examinations were delayed by approximately 2.5 years and conducted alongside junior batches, with results declared on January 19, 2019.

Source reference: para. 2

The petitioners sought a writ of mandamus to compel the Respondent State to grant them monetary benefits under the trained pay scale effective from the actual date they completed their training, rather than the date of result declaration.

Source reference: para. 3

They relied on prior judicial precedents and administrative letters issued by the Director, Primary Education.

Source reference: para. 3, 4
02

Issues

1. Whether the petitioners are entitled to the financial benefits of the trained pay scale effective from the date of completion of their training rather than the date of the declaration of examination results.

Source reference: para. 3, 6
03

Law Applied

The Court relied on the legal principle established in CWJC No. 7938 of 2020, as affirmed by the Division Bench in LPA No. 456 of 2021.

Source reference: para. 6

This principle dictates that a teacher's entitlement to a trained pay scale should be recognized from the date of completion of training when delays in examination are administrative in nature.

Source reference: para. 6

This doctrine was further solidified by the Hon’ble Supreme Court’s refusal to interfere in SLP (Civil) Diary No(S). 66035 of 2025.

Source reference: para. 6

Additionally, the court took note of Letter No. 1687 dated 21.05.2016 issued by the Director, Primary Education, which previously extended such benefits to similarly situated teachers.

Source reference: para. 4
04

Reasoning

The Court found that the legal grievance raised by the petitioners was no longer res integra (an unsettled point of law), as the issue had already been concluded by both the Single Judge and the Division Bench of the Patna High Court, and subsequently affirmed by the Supreme Court.

Source reference: para. 6

The Court reasoned that since the petitioners were duly appointed and had completed their training, the administrative delay in conducting examinations (which took 2.5 years) should not deprive them of the financial benefits of the trained pay scale from the point of training completion.

Source reference: para. 2, 6

The Counsel for the State did not contest the legal principle but requested individual examination of each petitioner’s service record to ensure they matched the criteria set out in the cited precedents.

Source reference: para. 5
05

Holding

The Court disposed of the writ petition with a direction to the petitioners to file separate applications before the Director, Primary Education.

The Director is ordered to examine each case individually and, if found identical to the cited precedents, grant the same relief (monetary benefits of the trained pay scale from the date of training completion) within a period of 12 weeks from the receipt of the order.

Source reference: para. 7, 8
Patna High Court

Original Court PDF

Vikram MishravsThe State of Bihar

Patna High Court · July 24, 2026

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