The Rajasthan High Court has affirmed a foundational principle of administrative equity: candidates selected in the same recruitment process must be treated as a single unit for pay and increment purposes, irrespective of their individual dates of joining. This ruling resolves long-standing disparities in service benefits and reinforces the constitutional mandate of equal treatment under Article 14.
Background & Facts
The Dispute
The petitioners, two school lecturers appointed through the same recruitment process conducted by the Rajasthan Public Service Commission, were denied parity in annual grade increments because they joined after 30 June 2017. While their peers appointed earlier received increments on the standard cycle, the petitioners’ increments were deferred, resulting in a persistent pay gap despite identical qualifications, seniority in selection, and job roles.
Procedural History
- 2023: The respondents issued an order (Annex.7) denying incremental parity, citing Rule 12 of the Rajasthan Civil Services (Revised Pay) Rules, 2017, which tied increments to actual date of joining.
- 2024: The petitioners filed writ petitions before the High Court challenging the discriminatory application of the rule.
- January 2026: The Court delivered a parallel judgment in Jitendra Kumar & Ors. v. State of Rajasthan, directly addressing the same legal issue.
Relief Sought
The petitioners sought a declaration that the differential treatment violated Articles 14 and 16 of the Constitution. They requested that all candidates selected in the same recruitment be granted uniform annual grade increments based on the date of selection, not the date of joining.
The Legal Issue
The central question was whether the Rajasthan Civil Services (Revised Pay) Rules, 2017, permit the denial of annual grade increments to candidates selected in the same recruitment merely because they joined after 30 June 2017, thereby creating an arbitrary pay disparity.
Arguments Presented
For the Petitioner
Counsel for the petitioners relied on State of Punjab v. Davinder Singh and K. Sankaran v. State of Tamil Nadu to argue that classification based on date of joining within the same recruitment batch lacks reasonable nexus with the object of pay fixation. They contended that the rule, as applied, violated the principle of equal pay for equal work and created an irrational classification.
For the Respondent
The State argued that the rule was designed to incentivize prompt joining and that administrative convenience justified the distinction. They cited internal guidelines and past practice to defend the differential treatment, asserting that the rule was not discriminatory but procedural.
The Court's Analysis
The Court rejected the State’s argument that administrative convenience could override constitutional equality. It held that candidates selected through a common merit-based process occupy the same position in the service hierarchy and must be treated identically for all service benefits, including increments.
"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."
The Court emphasized that the Rajasthan Civil Services (Revised Pay) Rules, 2017 must be interpreted harmoniously with Article 14. The distinction based on joining date was found to be arbitrary and without any rational basis, as the selection process itself was uniform. The Court further directed that any anomaly arising from prior incorrect application of the rule must be corrected by rationalizing records, with notice to affected parties.
The judgment explicitly overruled the notion that date of joining could override date of selection in determining service benefits for candidates in the same recruitment cycle.
The Verdict
The petitioners succeeded. The Court held that pay parity must be granted to all candidates selected in the same recruitment, irrespective of their date of joining. The impugned order was set aside, and the State was directed to correct records within one month to ensure uniform increments based on selection date.
What This Means For Similar Cases
Pay Parity Overrides Administrative Dates
- Practitioners must now challenge any service rule that links increments, promotions, or pay fixation to joining date when selection occurred through a common process.
- Government departments cannot justify pay disparities under the guise of "administrative convenience" if the selection was merit-based and uniform.
Rule Interpretation Must Align With Constitutional Equality
- Statutory rules must be read in a manner that avoids arbitrary classification. Where a rule creates inequality among identically situated persons, courts will intervene.
- In service law matters, the date of selection is the decisive factor for determining seniority and incremental benefits, not the date of reporting.
Correction of Past Injustices Is Mandatory
- The Court’s directive to "rationalize and correct" records establishes a precedent for retrospective relief in similar cases.
- Affected employees who were denied increments due to delayed joining may now file claims for arrears, provided they were part of the same recruitment batch.
