Sanjay Kumar Upadhyay vs State of Jharkhand; 2025 INSC 1445 - Precedent - Bihar Reorganization Act -Service Law - Pay Scale Parity

Bihar Reorganization Act 2000-Section 34- Judicial orders of the Patna High Court continue to bind the Successor State. (Para 31)

Precedent - . Once it is established that the factual matrix is identical and the legal issue involved is the same, the principle of judicial discipline demands that similar relief be granted to similarly situated persons. (Para 23) Similarly situated persons should be extended the benefit of judicial declarations without approaching the court individually - To hold otherwise would be to encourage multiplicity of litigation and deny the beneficial effect of judicial pronouncements to those who are entitled to it. (Para 28) When a decision of a coordinate Bench of the same High Court is brought to the notice of the Bench, it is to be respected and is binding subject to right of the Bench of such co-equal quorum to take a different view and refer the question to a larger Bench. It is the only course of action open to a Bench of co-equal strength, when faced with the previous decision taken by a Bench with same strength. (Para 22)

State - Model Employer- Financial implications and administrative convenience cannot override constitutional guarantees against arbitrary discrimination. The State, being the model employer, cannot plead its own inefficiency or negligence to deny legitimate rights to its employees. (Para 32)

Service Law - in matters involving pay scale parity based on removal of anomalies, the cause of action continues from month to month as long as the anomaly persists. Every month when the employee receives lesser pay than his similarly situated counterparts constitutes a fresh cause of action. (Para 24)

Constitution of India - Article 14- The principle of equality enshrined in Article 14 brooks no discrimination between persons who are similarly situated, and any differential treatment must be based on intelligible differentia having a rational nexus with the object sought to be achieved. (Para 30)