Summary of the Judgment
Case Name: Indian Council of Agricultural Research (ICAR) & Anr. v. Rajinder Singh & Ors.
Date of Judgment: 22nd August 2024
Judges: Hon’ble Justice J.K. Maheshwari and Hon’ble Justice Rajesh Bindal
Acts & Sections: Societies Registration Act, 1860; Article 14 of the Constitution of India
Introduction
The judgment in the case of Indian Council of Agricultural Research & Anr. v. Rajinder Singh & Ors. delivered by the Hon’ble Supreme Court on 22nd August 2024, revolves around the issue of whether technical personnel employed by the Indian Council of Agricultural Research (ICAR) are entitled to the same financial benefits as scientists when they acquire a Ph.D. degree during their service career.
Background of the Case
The appellants, ICAR, challenged the decision of the Delhi High Court, which had upheld the order of the Central Administrative Tribunal (CAT). The CAT had directed ICAR to extend the benefit of two advance increments, which were available to scientists upon acquiring a Ph.D. degree, to the technical personnel as well.
The root of the dispute lies in a circular issued by ICAR on 27th February 1999. This circular revised the pay scales for scientists following the recommendations of the Fifth Central Pay Commission. It also provided incentives for obtaining higher qualifications. Specifically, the circular allowed scientists to receive two advance increments upon obtaining a Ph.D. during their service. The respondents, technical personnel at the Indian Agricultural Research Institute (IARI), a unit under ICAR, sought the same benefit upon acquiring their Ph.D. degrees, arguing that their work was integral to research, and thus, they should not be discriminated against.
Contentions of the Parties
The appellants argued that the circular explicitly applied only to scientists, who are distinct from technical personnel in terms of their roles, qualifications, and service rules. They contended that extending the same benefits to technical staff would amount to an unjustified equalization of two categories of employees who are governed by different sets of rules and have different job responsibilities. The appellants further argued that the High Court and the CAT erred in invoking Article 14 of the Constitution of India, which guarantees equality before the law, to equate technical personnel with scientists.
On the other hand, the respondents contended that since they were encouraged to pursue Ph.D. degrees through the extension of study leave regulations originally meant for scientists, they should also be entitled to the financial benefits associated with acquiring such a degree. They argued that their enhanced qualifications directly contributed to their ability to assist in research, and hence, they should not be denied the same benefits as scientists.
Observations of the Supreme Court
The Supreme Court, through the judgment authored by Hon’ble Justice Rajesh Bindal, scrutinized the distinctions between the two categories of employees under ICAR: the Agricultural Research Service (ARS) and the Technical Service (TS). The Court observed that both services were constituted with distinct roles and governed by separate sets of rules. The ARS, to which scientists belong, involves personnel directly engaged in agricultural research and education, whereas the TS involves personnel who provide technical support in various capacities.
The Hon’ble Court highlighted that the Bye-laws 21 of ICAR’s Rules and Bye-laws clearly classify scientific and technical personnel into distinct categories, each with its own set of recruitment rules, qualifications, and promotional avenues. The Court noted that the incentives, including the two advance increments for acquiring a Ph.D., were specifically part of the pay package designed for the ARS cadre, which followed the University Grants Commission (UGC) pay scales. In contrast, the pay scales for technical personnel were aligned with those recommended for Central Government employees, without any provision for additional incentives for obtaining higher qualifications during service.
“Merely after having Ph.D. qualification, the technical personnel will not become eligible for grant of two advance increments when the same has not been recommended for them.”
The Court rejected the respondents’ argument that the extension of study leave regulations to technical personnel implied an entitlement to financial benefits similar to those given to scientists. The Hon’ble Justices clarified that the purpose of extending study leave was to encourage technical personnel to improve their qualifications, not to promise any financial incentives.
Application of Article 14 of the Constitution
A significant aspect of the respondents’ case was the invocation of Article 14 of the Constitution, arguing that denying them the same financial benefits as scientists constituted discrimination. The Supreme Court, however, found this argument untenable. The Court emphasized that Article 14 does not mandate absolute equality among all employees; rather, it permits reasonable classification based on intelligible differentia that distinguishes one group from another.
“In any institution, incentives may be given to a particular category of employees to get higher qualifications during service, considering their job requirements. Merely because different set of employees, who may be working in aid but governed by different set of rules and having different duties to discharge, also obtain that qualification, will not entitle them to the benefits which were extended to different set of employees by the competent authority.”
Conclusion
The Supreme Court concluded that the CAT and the Delhi High Court had erred in equating the two distinct categories of employees, thereby granting the technical personnel benefits that were not intended for them under the relevant service rules. The Court allowed the appeal filed by ICAR, setting aside the orders of the CAT and the Delhi High Court. The original applications filed by the respondents were dismissed, thereby denying them the two advance increments for acquiring a Ph.D. degree.
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