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Saturday, February 15, 2014

A NOTE ON SALIENT FEATURES OF JAIPUR JUDGMENT OF 12-1-2010



SALIENT FEATURES OF THE JAIPUR SJB ORDER DATED  12/1/2010 AND ITS MAJOR IMPLICATIONS

·        W.P. No. 6676/1998 was filed   by Mr Asthana at Jaipur HC  Bench when  there was no revision of wages  for LIC employees  due from 1/8/1997.The  petition  was only to remove the DR anomaly  that arose out of the Appendix IV  of LIC Pension Rules, 1995 which  specified slabs  which were at variance with the  slabs for in-service employees resulting in reduced  DR for pensioners  on account of unequal  DR neutralization..

·        This petition preceded the settlement of wage revision  w.e.f 1/8/1997  notified in 2000 and  was much before the LIC Board Resolution dated 24/11/2001.The Board decided  in its   Resolution  that (1) the proposal made by the Federation  of  rectifying the DR anomaly  from 1/11/1993 should be given effect to and (2) the DR should be merged  with Basic Pension at 1740 points of AICPI( as at 1/8/1997) and Pension should be upgraded with  11.25% weightage as was done for in-service employees.

·        As far as the concept of upgradation  of pension with weightage   was concerned, by implication, this principle would  have to be adopted  in future wage revisions  also, but which did not arise immediately at that point of time.( The wage revision  w.e.f  1/8/2002 was notified only in  2005).

·        From 1/8/1997 onwards, 100% DR neutralization was effected for both in-service employees and pensioners with uniform pattern of DR for both categories.

·        Mr Asthana along with other petitioners, filed another writ petition 654/2007 after the above developments .In this petition it was pointed out before the Court that there was disparity in pensions whereby later retirees (after wage revision dates) in lower cadres were paid more pension than higher cadre officers who retired before wage revisions. A case was thus made out for revision of pensions with every wage revision for existing pensioners also. The landmark judgment of the Supreme Court in D.S.Nakra  vs Union of India  and other  judgments  relevant for revision of pensions were extensively  quoted by the petitioners.

·        Five out of the 27 writ petitioners were those who retired between 1/8/1997 and 31/7/2002.

·        In its order dated 12/1/2010, the Single Judge Bench of Jaipur, headed by Justice Bhandari allowed both the petitions, i.e (1) the petition No 6676/1998 praying for removal of DR anomaly and unequal neutralization( referred to as lack of 100% neutralization) of DR from 1/11/1993 and (2) the other petition No 654/2007 praying for revision of pension whenever wage revisions are effected for in service employees.

·        The operative  parts  of the order are as follows:

Ø  “The Respondent Corporation is directed to take a decision for implementation of the resolution dated 24.11.2001 passed by the Board”.

This means that the DR anomaly from 1/11/1993 existing for pre-August 1997 retirees should be removed and pension should be upgraded by merging DR on 1/8/1997 with appropriate weightage .

Ø  “The respondent Corporation cannot provide different criteria for grant of dearness allowance to the existing pensioners based on cut off date i.e. 31.7.1997”.

What this means:

Here  the Court  has  taken note of  the  change in pattern of  the DR  calculation  ensuring  parity between in-service employees and pensioners with 100% DR neutralization that has been adopted in the wage revisions  effective from 1/8/1997 onwards. This is covered in the Board Resolution when it talks about giving effect to the proposal from 1/11/1993.  

Ø  “The benefit arising out of the directions above would, however, be considered by the respondent Corporation so that every retired employee may get the same benefit”.

What this means:

By this, the Court has clearly focused on the prayer in WP No 654/2007 for revision of pension for existing pensioners whenever wage revisions for in-service employees take place. As a corollary, not only all the Pre-August 1997 retirees, but also the post-July 1997 retirees should get the benefit of revision of pension  arising out of wage revisions  taking place after their dates of retirements.

Although the LIC Board Resolution  dt 24/11/2001, by implication, is  inclusive  of merger of DR  with Basic Pension on every wage revision date with suitable weightage , the last sentence of the operative portion of the Jaipur Single Judge Bench Order  dt 12/1/2010 over-rules any scope  for  restrictive interpretation of the Board Resolution.

Finally another point to be borne in mind is that the “weightage” mentioned in the Board Resolution is  obviously intended to ensure that  when merger of DR  with Basic Pension and upgradation is effected , the revised pension should increase in tandem with the  increase that is secured in Basic Pay  by in-service employees on wage revision. Such parity can be achieved only by stage –to-stage revision.