Service Law- Compassionate appointments -Apex Court rejected the claim of Petitioner and set aside High Court order on the ground of non existence of a State policy and considerable delay and Applicant not diligently pursuing their claims.

 Compassionate appointments in India have its roots in Article 39 of the Directive Principles of State Policy. It  is a provision made to provide employment to a dependent family member of a deceased government employee. The purpose of this provision is to alleviate the financial hardship faced by the family after the untimely demise of the employee, and to provide them with a means of sustenance. Compassionate appointments are granted based on grounds and conditions, specific rules and guidelines set by the respective state or central government.

·         Grounds for compassionate appointment in India:

  1. Death of the employee: The primary ground for compassionate appointment is the death of the government employee. This includes cases where the employee dies while in service or due to an injury or illness directly attributable to the performance of official duties.
  2. Financial hardship: Compassionate appointment is considered when the family of the deceased employee is in financial distress and unable to sustain themselves due to the loss of the employee's income. The appointment aims to provide support to the family by offering a job.
  3. Eligible dependent family member: The appointment is generally granted to a dependent family member of the deceased employee. This usually includes the spouse, son, daughter, or sibling who meets the prescribed eligibility criteria set by the respective government or organization.
  4. Availability of suitable vacancy: Compassionate appointment is subject to the availability of a suitable vacancy in the organization. The organization should have an open position that can be filled through compassionate appointment without compromising the efficiency and functioning of the institution.
  5. Lack of alternative means of support: The family should demonstrate that they do not have any other adequate means of support or livelihood. This could include factors such as the absence of another earning member in the family, limited job opportunities in the locality, or the dependent's inability to find suitable employment due to various reasons.
  6. Time limit for application: There is usually a specific time limit within which the application for compassionate appointment needs to be submitted. This ensures that the request is made in a timely manner and prevents undue delay in processing the appointment.
  7. Merit-based consideration: In some cases, compassionate appointment may also require the dependent to meet certain merit-based criteria, such as educational qualifications, skill set, or relevant experience. This helps ensure that the appointed person is capable of fulfilling the duties of the position.
  8. Rules and regulations: The appointment is governed by specific rules and regulations set by the concerned government or organization. These rules outline the eligibility criteria, application process, and the maximum age limit for considering compassionate appointments. The applicant must meet the prescribed qualifications and other requirements.
  9. Discretionary power of the employer: The authority granting compassionate appointment holds discretionary power to determine whether to grant or reject an application. The decision is made after assessing the merits of each case, including the financial condition of the family, the availability of suitable vacancies, and the overall circumstances.

It is important to note that the grounds for compassionate appointment may vary across different government departments and organizations in India. Therefore, it is advisable to refer to the specific rules and guidelines applicable to the concerned institution for accurate and up-to-date information regarding compassionate appointments.

·         Latest judgment and Principles set out by Apex Court on compassionate appointment in India:- Apex court in case of State of West Bengal v. Debabrata Tiwari And Ors. Etc.| 2023 LiveLaw (SC) 175 | Civil Appeal Nos. 8842-8855 of 2022 of 2023| 3rd March, 2023 held that:

 

“...the operation of a policy/scheme for compassionate appointment is founded on considerations of immediacy. A sense of immediacy is called for not only in the manner in which the applications are processed by the concerned authorities but also in the conduct of the applicant in pursuing his case, before the authorities and if needed before the Courts.”

 

·         Grounds for rejecting claim of Compassionate Appointment by Apex Court:

 

1.      Existence of a State policy is sine qua non for making compassionate appointments.

2.      Considerable delay and Applicant not diligently pursuing their claims.

 

·         Principles summarized by Apex Court for compassionate appointment in India:

 

a.      Provision to enable the family of the deceased to get over the sudden financial crisis. Compassionate appointment makes a departure from the general provisions providing for appointment to a post by following a particular procedure of recruitment

b.      Appointment on compassionate grounds is not a source of recruitment. It aims to see that the dependents of the deceased are not deprived of the means of livelihood. It only enables the family of the deceased to get over the sudden financial crisis.

c.       Compassionate appointment is not a vested right which can be exercised at any time in future. Compassionate employment cannot be claimed or offered after a lapse of time and after the crisis is over.

d.      Compassionate appointment should be provided immediately to redeem the family in distress. It is improper to keep such a case pending for years.

e.      Factors determining as to whether the family is in financial crisis:  All relevant aspects must be borne in mind including the income of the family, its liabilities, the terminal benefits if any, received by the family, the age, dependency and marital status of its members, together with the income from any other source.

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