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Monday, April 01, 2024

EXTRACTS FROM SUPREME COURT JUDGMENT DATED 31/3/2016

Para 2

“It appears that the appellant, the Life Insurance Corporation of India (for short' 'the Corporation') at one point of time was enthusiastic to confer certain benefits on the respondent-employees, may be without appreciating the legal nuances but its action irrefragably instilled a concrete hope in thousands of employees”.

My remarks

Dictionary meaning of ‘irrefragably’:

Not liable to be refuted or disproved; indisputably

The SC Bench has sensed that at one point of time LIC was enthusiastic to provide benefits to retired employees and instilled hope in thousands of employees(retirees).

Para 8

Minutes of the Board Meeting dated 24/11/2001

“An index linked Pension Scheme in lieu of Corporation's Contribution to Provident Fund (CCPF) was introduced in the Corporation vide Central Government Notification dated 28.06.1995. The Scheme provides for payment of pensionary benefits with effect from 01.11.1993. The employees of the Corporation, who retired between 01.11.1986 to 31.10.1993, are also covered under the scheme for pensionary benefits.

2. At the time of notification of the Pension Rules, the scales of pay and allowances of the employees of the Corporation were linked to All India Consumer Price Index (AICPI) 800(?) points. After the notification of the Pension Rules, the pay scales and allowances of the employees of the Corporation have been revised on two occasions – first in the year 1996 by linking it to AICPI 1148 Points and again in the year 2000 by linking it to AICPI 1740 Points. The revision in the year 1996 was made effective retrospectively from 01.08.1992 and the revision in the year 2000 was made effective retrospectively from 01.08.1997. Consequent upon the revision of pay scales, the Pension Rules were suitably amended to give effect to payment of pension commutation value and family pension as per the revised scales of pay and allowances. However, the Dearness Relief on pension is being paid to different generations of pensioners (depending upon their date of retirement) on a graded structure upto 31.07.1997 as per the rates given in Appendix-IV of the Pension Rules governing the rates of Dearness Relief is given in Annexure-I to this note.

 3. It may be observed from the rates of Dearness Relief as given in Annexure-I, that there are three different rates prescribed for different groups of pensioners depending upon their date of retirement. Due to the different rates of Dearness Relief to different groups of pensioners, the real value of pension, which is being eroded over a period of time is not being protected besides causing administrative inconvenience. It has thus become necessary to rationalize the Dearness Relief structure and provide a suitable updation formula to upgrade the basic pension to the employees of the Corporation who have retired prior to 01.08.1997. It may be mentioned that such a provision to upgrade the pension due to periodic revision in case of Central Government employees is incorporated in the Central Civil Services (Pension) Rules, on the basis of which the LIC of India (Employees) Pension Rules have been drafted.

 4. In view what has been stated in Para 3 above, it is suggested that the following updation formula to upgrade the basic pension/family pension in respect of employees who have retired between 01.01.1986 to 31.07.1997 may be adopted.

 a. The basic pension/family pension payable in relation to AICPI 600 points or 1148 points, as the case may be, shall be upgraded by merging the Dearness Relief payable upto AICPI 1740 points, and b. On the pension so upgraded, Dearness Relief of 0.23% of basic pension shall be paid or become recoverable for every 4 point rise or fall of AICPI from 1740 points. It is suggested that the above amendment shall be made from the date of its notification in the official gazette and no arrears on account of Pension/Family Pension/Commutation Value or Dearness Relief shall be payable. The one-time financial implication of the above proposal has been actuarially determined to be Rs.51.37 Crore.”

(underlining mine)

My remarks

These minutes of the LIC Board meeting clearly record that different rate of DR result in erosion of real value of pension over a period of time and not being protected. The necessity for rationalization of DR formula and provide a suitable formula for  updation for pre-August 1997 retirees has been stressed.

It has also been mentioned that such a provision to upgrade the pension due to periodic revision  in case of Central Government  employees is incorporated in the CCS(Pension) Rules.

It is also clearly stated that LIC (Employees) Pension Rules Have been drafted on the basis of CCS (Pension) Rules.

The Minutes of the Board Meeting clearly reinforce the importance and applicability of Rule 56 of the LIC Pension Rules 1995.

Para 9

Resolution passed by the Board on 24/11/2001 on the basis of the Minutes

“Amendment to LIC of India (Employees) Pension Rules, 1955(?1995) – UPGRADING OF Basic Pension to AICPI 1740 Points and 100% DA neutralization thereon in respect of Retirees prior to 01.08.1997: Executive Director (Personnel), introducing the subject mentioned that there were three different rates for different groups pensioners at present depending upon their dates of retirement, which causes considerable administrative inconvenience. Chairman pointed out that he has since received a communication for Dr. S. Ram Khanna, Board Member, which refers to his meeting with the Retirees Federation and requests for examining the proposals as per Board Note in line with the demands made by the Federation viz. Giving effect to the proposals by 01.11.1993 and upgradation by giving weightage of 11.25% as in the case of in-service employees. Chairman pointed out that these have been considered before placing the matter to the Board and it was felt that the same would increase the financial burden very substantially and may be unaffordable for the Corporation. Chairman pointed out that the implications of the proposal made have been actually determined at Rs.51.37 crore and the annual outlay would be in the region of 5 to 6 crore. After some discussion, the Board approved the proposal and suggested that it should be implemented prospectively after obtaining Government approval.”

 

My remarks

Reading the Minutes together with the Board Resolution, it is clear that the Board approved the proposal for upgradation for pension w e f 1/8/1997 for the pre-August 1997 retirees subject to Government approval. The import of the Board Resolution is that there should be one rate of DR for all pensioners on basic pension irrespective of the date of retirement. It is possible only with upgradation of pension with wage revision. It is pertinent to note that on that date the second  Wage revision after the Notification of LIC Pension Rules was the one dated 22/6/2000 effective from 1/8/1997 merging DA with Basic Pay at AICPI of 1740.  the first one being that on 18/7/1996 revising wages from 1/8/1992 on merger of DA at AICPI of 1148.Thus the effect of the Board recommendation as on date is that all the generations of employees retired upto 31/7/2017 become entitled to upgradation of pension from the first effective date of wage revision after their retirement. What is more even the employees covered by LIC Pension Rules in service will be entitled to upgradation of pension similarly after their retirement in future. Now with the Notification of wage revision w e f 1/8/2022, the latest generation of retirees upto 31/7/2022 will also get entitled to upgradation of pension.

 

 

Para 16

“16. Having stated so, in all possibility, we would have proceeded to record the conclusion but, a significant one, the controversy of this nature does not see the sunset with such immediacy.”

My Remarks

This is a very important observation by the SC Bench as, if it had just stopped with setting aside the three High Court judgments, that would have been the end of the road for LIC pensioners. A lifeline has been provided by the SC to LIC pensioners  later in the judgment where 6 Civil Appeals by Pensioners/Pensioner bodies are now to be adjudicated by SC.

Para 17

We are of the considered opinion that when the issue of constitutional validity of Para 3A to the Appendix was raised, the same deserved to be addressed by the High Court.

My Remarks

This seems to have been omission on the part of Jaipur Benches and also DHC and Chandigarh HC Benches

Para 18

18. Mr. Gupta, learned senior counsel appearing for the respondents, endeavoured hard to impress upon us to deal with the same, but as we find certain facts are to be adverted to and the pleadings are not adequate, we think it seemly to restrain from the same.


 

My Remarks

SC was particular that Para #A Constitutional validity should be adjudicated at the High Court level.

Para 21

It is urged by Mr. Gupta that once the employees are covered under Para 3A, being retirees after the cut-off date, the benefit cannot remain static but has to change with the pay revisions regard being had to the price index, for otherwise the provision does not spring to life and, eventually, paves the path of arbitrariness.

My Remarks

This is a significant intervention by Senior Counsel to emphasize on extending the need for upgradation of pension beyond pre-August 1997 retirees

Para 22

Be it stated, there are two categories of employees, namely, the employees who have retired prior to the cut-off date i.e. 1st 23 August, 1997, as a consequence of which they are not getting the benefit of dearness relief, and the employees who have retired after the said date but are not extended the benefit of dearness relief despite subsequent pay revisions. Needless to say, the quantum of pension is affected.

My remarks

Tone set by SC for considering upgradation of pension with every wage revision.

Para 23

23. Regard being had to the piquant situation, we are inclined to set aside the orders passed by the High Courts of Rajasthan, Delhi and Punjab & Haryana at Chandigarh and transfer the writ petitions from the High Courts of Rajasthan and Punjab & Haryana to the High Court of Delhi, which will decide the constitutional validity of Para 3A of the Appendix to the Rules, as argued by Mr. Panchu, learned senior counsel appearing for the respondents, and also deal with the cases of the persons, who have retired after the cut-off date, consider the contentions raised by Mr. Gupta, learned senior counsel and the other contentions to be raised.

My Remarks

Lifeline provided by the SC Bench for LIC Pensioners by remanding the case to Delhi HC.

Para 26

We feel the pain while remanding the matter, but we have no option as the pleadings are not adequate as it should have been while assailing a constitutional validity of a provision. It is well settled in law that he who assails the constitutional validity of a statutory provision or a rule, has to specially assert the grounds for such challenge.

The purpose of saying all this is as the learned counsel for the respondents would agonizingly contend that the amount of pension the respondents are getting is a paltry sum and it is difficult to sustain in the present day. That apart, the Corporation should have been gracious enough to recognize the services rendered by them and the Union of India should have come with an affirmative response when the resolution was passed by the Corporation.

My Remarks

SC Bench sympathised, but pleading was inadequate to facilitate granting relief for pensioners.

 

Para 28

It does not require Solomon's wisdom to state that an interim order is an interim order and does not have any impact at the time of final verdict especially in such a situation and, therefore, we direct that it shall be applicable to the similarly placed persons.

My Remarks

This was in respect of the interim relief of 20% sanctioned on 7/5/2015 and also the 40% interim relief sanctioned in the judgment( including earlier 20%) dated 31/3/2016.