In a significant decision, the Supreme Court of India reaffirmed the constitutional guarantee of equality under Article 14, declaring that differential treatment in employment benefits is unjustifiable. The judgment, delivered by a bench comprising Justice Pamidighantam Sri Narasimha and Justice Sandeep Mehta, reversed the Punjab and Haryana High Court’s decision, ensuring that work-charge employees are entitled to equal benefits under the Proficiency Step-up Scheme, 1988.
Background of the Case
The appellants, Gurmeet Singh and others, were work-charge employees under the Irrigation Department of Punjab, working on the Ranjit Sagar Dam project. Their services were regularized under a policy circular issued by the Punjab government in 1996, which recognized prior work-charge service for pensionary and other benefits. Despite this, they were excluded from the benefits of the Proficiency Step-up Scheme, 1988.
The appellants approached the Punjab and Haryana High Court, seeking recognition of their work-charge service for benefits under the scheme. However, both the Single Judge and Division Bench denied their claims, equating the Proficiency Step-up Scheme with the Assured Career Progression Scheme (ACPS), 1998, and ruling that prior work-charge service did not qualify for benefits under either scheme.
Legal Issues Involved
The case revolved around two critical legal questions:
1. Whether work-charge service should count as qualifying service under the Proficiency Step-up Scheme, 1988.
2. Whether the exclusion of the appellants violated Article 14 of the Constitution, which guarantees equality before the law and prohibits discrimination.
Key Observations
1. Equality in Benefits:
The court underscored that similarly placed employees had been granted benefits under the Proficiency Step-up Scheme without judicial orders. Excluding the appellants amounted to arbitrary discrimination.
2. Judicial Precedents:
The court relied on precedents where similar claims had been upheld, including the Industrial Tribunal’s decision recognizing work-charge service for the scheme, later affirmed by the Supreme Court.
3. Government’s Responsibility:
The court reminded the State of its obligation to ensure non-discriminatory treatment, especially when circulars and policies explicitly grant such benefits.
Supreme Court’s Decision
The Supreme Court examined the policy circulars and past judicial precedents. The bench observed that the High Court failed to distinguish between the Proficiency Step-up Scheme, 1988, and the ACPS, 1998. Highlighting the government circular dated March 13, 1996, the court noted that it explicitly recognized work-charge service as qualifying for pensionary and other consequential benefits.
Justice Mehta, delivering the judgment, emphasized:
“Differential treatment could not have been meted out to the appellants herein who formed a part of the same establishment and were similarly situated to the employees who were granted the benefits under the Proficiency Step-up Scheme, 1988.”
The court held that denying the appellants benefits under the Proficiency Step-up Scheme violated the principle of equality enshrined in Article 14.
Directions of the Court
The Supreme Court directed that the appellants’ work-charge service be counted as qualifying service under the Proficiency Step-up Scheme, 1988. The court mandated that all monetary benefits arising from this decision be paid within six months.
“This decision restores the rightful benefits to employees who have long been denied their due, reinforcing the judiciary’s commitment to upholding constitutional equality,” stated Senior Advocate P.S. Patwalia, representing the appellants.
Case Details
– Case Name: Gurmeet Singh & Ors. vs. State of Punjab & Ors.
– Case Number: Civil Appeal Nos. 17529-17530 of 2017
– Bench: Justice Pamidighantam Sri Narasimha and Justice Sandeep Mehta
– Counsel for Appellants: Senior Advocate P.S. Patwalia
– Counsel for Respondents: Advocate Shadan Farasat (Additional Advocate General, Punjab)
