INDIAN COUNCIL OF AGRICULTURAL RESEARCH THROUGH THE DIRECTOR GENERAL [ Appellant(s)] Vs. RAJINDER SINGH AND ORS. [ Respondent(s)]
CIVIL APPEAL NOS. 97-98 OF 2012
(2JB, J.K. MAHESHWARI and RAJESH BINDAL JJ., delivered by Rajesh Bindal, J.)
In the case of Indian Council of Agricultural Research through the Director General and Anr. vs. Rajinder Singh and Ors., decided on August 22, 2024, the Supreme Court clarified that employees governed by distinct rules and responsibilities are not entitled to the same benefits as others, even if they have the same qualifications. The two-judge bench, comprising Justice JK Maheshwari and Justice Rajesh Bindal, reviewed a situation where the Central Government’s pay scales were revised based on the Fifth Central Pay Commission’s recommendations. The Indian Council of Agricultural Research (ICAR) notified its field offices about the revised pay scales for various scientist positions. Discontented employees challenged the scheme before the Tribunal, which granted them benefits for obtaining a Ph.D. The ICAR’s appeal to the High Court was dismissed, with the High Court incorrectly equating scientists with technical staff.
The appellants argued that the Tribunal exceeded its jurisdiction by equating scientists and technical personnel, incorrectly assuming they should receive similar benefits due to working for the same organization. The Tribunal’s decision to grant advance increments for a Ph.D. to the respondents, who were technical personnel, was challenged. The appellants contended that such benefits were specifically allocated to scientists and were not applicable to other employee categories. They also highlighted that the extension of ARS Study Leave Regulations to technical personnel aimed only to encourage qualification improvement without financial benefits. The High Court’s dismissal of the writ petition, which upheld the Tribunal’s decision by misapplying Article 14 and wrongly equating different employee categories, was also contested. The appellants sought to overturn both the Tribunal’s and High Court’s decisions.
The respondents’ Senior Counsel argued that Entry 66 in List I of the 7th Schedule of the Indian Constitution, which covers standards in higher education and includes “research” and “technical” fields, supports their claim for equal treatment. They contended that, although scientists focus on research and technical personnel on technical aspects, both contribute to the research process. The Counsel highlighted that the Study Leave Regulations, 1991, extended to technical staff to undertake Ph.D. programs, were meant to enhance their contribution to research. Therefore, they argued that the Tribunal and High Court correctly granted advance increments to technical personnel, encouraging them to enhance their qualifications and research contributions.
The Supreme Court noted that different employee categories, despite having the same qualifications, are not automatically entitled to similar benefits due to their differing roles and rules. The Court found that the Tribunal and High Court erred in equating technical personnel with scientists and improperly granting advance increments. Consequently, the Supreme Court overturned the Tribunal’s and High Court’s decisions, dismissing the respondents’ applications.
