The Rajasthan High Court has affirmed a foundational principle of administrative equity: candidates appointed through the same recruitment process must be treated as a single unit for the purpose of annual grade increments, regardless of their individual dates of joining. This ruling resolves a systemic anomaly that had led to disparate pay fixation among equally selected employees, reinforcing the doctrine of equal treatment under service law.
Background & Facts
The Dispute
The petitioner, Laxmi Devi, a School Lecturer in Geography, was appointed through a competitive recruitment process conducted by the Department of Education, Government of Rajasthan. She was appointed after 30.06.2017, while other candidates selected in the same recruitment process had joined earlier. Despite being selected on identical criteria and holding the same post, her annual grade increments were delayed or denied on the basis of her later joining date, resulting in a lower pay scale compared to her peers.
Key Facts
- The petitioner was selected in a recruitment process conducted for the post of School Lecturer (Geography)
- She was appointed and joined service after 30.06.2017
- Other candidates selected in the same recruitment process joined prior to 30.06.2017
- The Rajasthan Civil Services (Revised Pay) Rules, 2017, were interpreted by the respondents to deny uniform increments based on date of joining
- The petitioner was denied parity in annual grade increments and consequential pay fixation
- She filed representations which were rejected by the authorities
- Impugned orders dated 29.08.2023 (Annex.7) and the final rejection order (Annex.9) upheld the discriminatory practice
Procedural History
- Date of appointment: Post-30.06.2017 (exact date not specified in judgment)
- 29.08.2023: First impugned order denying parity in increments
- Date of rejection: Final rejection order issued (Annex.9), exact date not specified
- 2026: Writ Petition No. 8429/2026 filed before the High Court of Judicature for Rajasthan at Jodhpur
- 12.01.2026: Judgment delivered in S.B. Writ Misc. Application No. 37/2026 (Jitendra Kumar & Ors. v. State of Rajasthan & Anr.) establishing the principle of pay parity
- 20.01.2026: Modified order in Jitendra Kumar case clarifying implementation
- 29.04.2026: Judgment in the present case delivered
Relief Sought
The petitioner sought:
- Declaration that the denial of uniform annual grade increments based on date of joining is illegal
- Direction to grant her annual grade increments from the same date as her peers selected in the same recruitment
- Correction of her pay scale to match that of other appointees in the same recruitment
- Quashing of the impugned orders dated 29.08.2023 and the rejection order (Annex.9)
The Legal Issue
The central question was whether the Rajasthan Civil Services (Revised Pay) Rules, 2017, permit differential treatment in the grant of annual grade increments among candidates selected in the same recruitment process solely on the basis of their date of joining, particularly when such difference undermines the principle of equal pay for equal service.
Arguments Presented
For the Petitioner
The petitioner’s counsel, Mr. M.L. Deora, argued that the differential treatment violated the principle of equality under Article 14 of the Constitution. He contended that since all candidates were selected through the same recruitment process, on the same criteria, and appointed to the same post, they must be treated as a single class for the purpose of service benefits, including annual grade increments. He relied on the precedent set in Jitendra Kumar & Ors. v. State of Rajasthan & Anr., which had already settled this issue.
For the Respondent
The respondents, represented by Mr. N.K. Mehta, did not contest the petitioner’s claim. They acknowledged that the issue was squarely covered by the earlier judgment in Jitendra Kumar and jointly submitted that the present petition should be decided in accordance with that order.
The Court's Analysis
The Court observed that the controversy was not novel and had already been authoritatively resolved in Jitendra Kumar & Ors. v. State of Rajasthan & Anr. The judgment dated 12.01.2026, as modified on 20.01.2026, had held that treating candidates selected in the same recruitment differently based on their date of joining created an arbitrary and irrational classification, violating Article 14.
"The respondents have to treat all such candidates as a single unit for grant of annual grade increments whether they have joined prior to 30.06.2017 or subsequent to 30.06.2017. Any anomaly arising due to adoption of such improper dates of joining for the purpose of granting one annual grade increment among the candidates appointed in the same recruitment shall be rationalized and shall be corrected."
The Court emphasized that the doctrine of equal pay for equal work extends to the grant of service benefits such as annual increments when the selection process, post, and qualifications are identical. The Rules, as applied, created an artificial distinction without any rational nexus to service efficiency or administrative necessity. The Court held that the date of joining cannot override the date of selection in determining service benefits for candidates in the same recruitment batch.
The Court further directed that the anomaly must be corrected by treating the date of selection as the common reference point for all increments, and that the respondents must make necessary corrections in official records after providing notice and hearing to affected parties.
The Verdict
The writ petition was allowed. The impugned orders dated 29.08.2023 and the rejection order (Annex.9) were set aside. The respondents are directed to treat all candidates selected in the same recruitment process as a single unit for the purpose of annual grade increments, irrespective of their date of joining after 30.06.2017. The respondents must correct the petitioner’s pay scale and increment history to match that of her peers, and are directed to complete all necessary revisions within one month from the date of receipt of a copy of this order.
What This Means For Similar Cases
Pay Parity Is Non-Negotiable in Uniform Recruitment
- Practitioners must now argue that any service rule creating differential benefits based on joining date within the same recruitment batch is constitutionally invalid
- Administrative departments must review all recruitment batches from 2017 onwards for parity violations
- Claims for arrears of increments can now be pursued with legal certainty
Correction of Records Is Mandatory, Not Discretionary
- The Court’s direction to "make necessary corrections in official records" imposes a positive duty on the State
- Notice and hearing must precede any revision, ensuring procedural fairness
- Failure to comply within the one-month deadline may attract contempt proceedings
Precedent Binding Across All Recruitments
- The Jitendra Kumar judgment now serves as binding precedent for all similar cases in Rajasthan
- Any future denial of parity on the same grounds will be considered a direct violation of this ruling
- Legal challenges can now be framed as enforcement of a settled legal principle, not as novel litigation
