E.S.P. Rajaram vs Union of India (2001)

16 Oct 2025 Landmark Judgements 16 Oct 2025

Law Points Raised

• Dispute over pay scale parity between Traffic Apprentices recruited before and after 15-05-1987.

• Validity of Railway Board Memorandum dated 15-05-1987 under Rule 1A of Indian Railway Establishment Code.

• Jurisdiction of Supreme Court under Article 142 to issue directions for doing complete justice.

• Challenge to the application of M. Bhaskar judgment to parties not heard.

• Principles of natural justice and finality of CAT orders.

 

[Judgment Source]

LINK

Ratio Decidendi

• The Court upheld the 15-05-1987 cutoff as non-arbitrary and reasonable.

• The Railway Board had legal authority to differentiate pay scales for new recruits.

• No recovery of excess payment already made to employees affected by conflicting CAT orders.

• Article 142 permits equitable relief even when statutory law differs.

• The principle of finality of judgments holds unless contradicted by binding SC precedent.

Final Ruling

• Appeal dismissed; no interference with M. Bhaskar judgment.

• Pre-1987 Traffic Apprentices not entitled to higher revised pay scale (Rs. 1600–2660).

• Employees who had already received higher pay due to final CAT rulings would not face recovery.

• Clarified Supreme Court's power to harmonize conflicting lower tribunal orders under Article 142.

• Status quo maintained regarding promotions and pay until further orders.

Relevant Paragraph Numbers

• Para 17 – Key conclusions from M. Bhaskar's case.

• Para 18 – Equitable relief and non-recovery directions.

• Referral Order – Constitution Bench reference.

• Para on Article 142 – Complete justice jurisdiction.

• Final paras – Dismissal and clarification of scope.

 

[Judgment Source]

LINK

Article Details
  • Published: 16 Oct 2025
  • Updated: 16 Oct 2025
  • Category: Landmark Judgements
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