Service Law-Equal Pay for Equal Work-once the employer is same, mode of recruitment, qualification for the post, nature of work and other responsibilities are same, such employees shall be governed by principal of 'equal pay for equal work', and there cannot be any denial of similar pay scale on any ground

 

Issue: Equal Pay for Equal Work –

Court of Adjudicature: Hon'ble High Court of Allahabad .

Parties Bhawani Prasad Sahu and 8 Ors  v. State of U.P.,Case details: Writ appeal No. 167 of 2014.Citation: (Allahabad) 2023(1) All WC 722 : 2023(1) ADJ 638Date of Decision : 14.12.2022.

Decision : ….once the employer is same, mode of recruitment, qualification for the post, nature of work and other responsibilities are same, such employees shall be governed by principal of 'equal pay for equal work', and there cannot be any denial of similar pay scale on any ground- PARA 16.

 

Case/Judgement referred by the Hon’ble Court :

1.   Randhir Singh v. Union of India (1982) 1 SCC 618

2.   Secretary, Finance Department v. West Bengal Registration Service Association, [1993] Supp I SCC 153.

3.   State of Haryana v. Haryana Civil Secretariat Personal Staff Association (2022) 6 SCC 72.

4.   State of Madhya Pradesh v. Seema Sharma Civil Appeal No. 3892 of 2022.

5.   State of Punjab v. Jagjit Singh (2017) 1 SCC 148.

Prayer before Hon’ble Court:

"(i) Issue a writ, order or direction in the nature of certiorari quashing the impugned order dated 7.4.2011, 8.12.2010, 22.9.2009, 7.10.2010, 11.3.2011, 30.12.2011, 1.4.2012 passed by the opposite parties as contained at Annexure No.1, 2, 3, 4, 5, 6 & 7. 

(ii) Issue a writ, order or direction in the nature of mandamus commanding the opposite parties to fix the pay scale of the petitioners equal to the pay scale of generator operator of Irrigation Department i.e. Rs. 4000-100-Rs.6000 with effect from 1.1.1996." 

Arguments before Hon’ble Court by Petitioner/s:

 

1.   Controversy is arising due to discrimination of pay scale of the similarly situated employees in two departments of State of U.P., i.e. Public Works Department (in short PWD) and Irrigation Department.

2.   Petitioners as well as generator operator of Irrigation Department are performing same duty, but petitioners were deprived from the pay scale of Rs.4000-6000/- and being paid the pay scale of Rs.3050-4590/-.

3.   Irrigation Department and PWD, both are department of State of U.P. and petitioners as well as generator operators of Irrigation Department are performing same work and duty, therefore, petitioners are also entitled for same pay scale as given to generator operators of Irrigation Department running the generators of over and above of 50 KVA.

4.   Case laws relied:

a.   Apex Court in the case of Randhir Singh v. Union of India and others reported in (1982) 1 SCC 618, where Apex Court has held that if two departments are under control of one Government and employees are having similar duty, no discrimination can be made in their salary and both sets of employees would be governed by principal of 'equal pay for equal work' and entitled for same salary.

b.   Apex Court in the matter of State of Punjab and others v. Jagjit Singh and others reported in (2017) 1 SCC 148.

 

Arguments before Hon’ble Court by Respondent/s:

 

c.   Petitioners cannot claim parity of pay scale as a matter of right.

d.   Merely similarity of designation or quantum of work cannot be a ground for equality of pay scale.

e.   Placed reliance upon the judgment of Apex Court in the matter of State of Madhya Pradesh v. Seema Sharma passed in Civil Appeal No. 3892 of 2022.

f.    Fixation of pay scale and determination of parity in duties is the function of the executive and scope of judicial review is very limited.

g.    Placed reliance upon the judgment of the Apex Court in the case of State of Haryana and another v. Haryana Civil Secretariat Personal Staff Association reported in (2022) 6 SCC 72.

Questions by Hon’ble Court to Respondent/s:

h.   Could not dispute this fact that Irrigation Department and PWD are the department of State of U.P. with equal status headed by Principal Secretary.

i.    Could not point out any difference about the nature of appointment of petitioners in PWD and other employees in Irrigation Department.

j.    Other Factual submissions so argued by the learned counsel for the petitioners could also not be disputed by the learned Standing Counsel.

Judgment of Hon’ble Court with reasoning and Judgments relied upon:

k.   Apex Court in the case of State of U.P. v. Randheer Singh (supra) and Apex Court has taken clear cut view that if two departments are under control of one Government and employees are having similar duty, no discrimination can be made in their salary and both sets of employees would be governed by principal of 'equal pay for equal work

l.    State of Punjab and others v. Jagjit Singh,The principle of 'equal pay for equal work', applies to cases of unequal scales of pay, based on no classification or irrational classification…

m.  Federation of All India Customs and Central Excise Stenographers (Recognized) case.

n.    Mewa Ram Kanojia case.

o.    Grih Kalyan Kendra Workers' Union case.

p.    S.C. Chandra case.

q.   Secretary, Finance Department v. West Bengal Registration Service Association and Ors., [1993] Supp I SCC 153.

 


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