Teachers obtaining professional qualifications on their own expenses while receiving full salary are ineligible for advance increments.

The petitioner was appointed as an Assistant Teacher in 1984 within the Tribal Welfare Department and was eventually promoted to Headmaster in 2009

In 2018, his services were merged into the School Education Department

In 2017, the petitioner obtained departmental permission to enroll in the D.El.Ed. (Diploma in Elementary Education) course at his own expense while continuing his service and receiving full salary

Upon successful completion in 2019, he claimed two advance increments based on applicable policy

His representation was rejected by the respondent authority on May 25, 2021, on the grounds that such increments are not permissible for teachers who obtained training while receiving full pay and allowances

The petitioner challenged this rejection in the High Court

1. Whether the petitioner is entitled to two advance increments for acquiring a D.El.Ed. qualification during the course of employment while receiving full salary and benefits

The Court primarily relied on the State Government’s Circular dated 11.05.2017, which clarifies the eligibility for advance increments following B.Ed./D.Ed./B.T.I. training

The rule establishes that teachers who complete such training during employment while receiving full salary, allowances, and annual increments are not entitled to additional advance increments

Furthermore, the Court noted that pursuant to a notification dated 17.06.1993, such professional qualifications became a mandatory requirement for the post of teacher, thereby negating the claim for additional incentives for acquiring them post-appointment

The Court examined the petitioner’s service history against the restrictive conditions of the 11.05.2017 Circular. It observed that although the petitioner completed the D.El.Ed. at his own expense, he remained in active service, drawing full salary and benefits throughout the training period

The Court reasoned that the Circular explicitly excludes such employees from receiving two advance increments to prevent double benefits

The Court further noted that the petitioner failed to challenge the validity of the 11.05.2017 Circular itself, which served as the legal basis for the rejection

Consequently, applying the text of the Circular to the undisputed facts, the Court found no arbitrariness in the respondent's decision to deny the increments

The High Court found that the respondent authorities correctly rejected the claim in accordance with State policy. Accordingly, the petition was dismissed, and no relief was granted