Introduction:

The Punjab and Haryana High Court has upheld an order granting a long-serving part-time Class-IV employee the minimum of the pay scale attached to the Group-D post against which he had been working, holding that the Chandigarh Administration could not deny the benefit to one employee after extending it to almost all similarly situated part-time employees.

A Division Bench comprising Justice Harsimran Singh Sethi and Justice Minderjeet Yadav dismissed the petition filed by the Chandigarh Administration and Others against an order passed by the Central Administrative Tribunal in favour of Nanu Ram. The Tribunal had directed that Nanu Ram be granted the minimum of the pay scale of the Group-D post against which he had been performing duties.

The High Court’s judgment, pronounced on August 24, 2026, arose from a dispute concerning the status and remuneration of part-time Class-IV employees engaged by the Chandigarh Administration. The Administration had engaged such personnel to perform Class-IV duties which continued to be required. Although described as part-time employees, they were working for approximately six hours a day, compared with the eight-hour working schedule applicable to regular employees.

Nanu Ram had rendered approximately 23 years of service with the Chandigarh Administration and had throughout been paid at the rates applicable to daily-wage or DC-rate workers. His claim before the Tribunal was for the minimum of the pay scale attached to the Group-D post against which he had been working.

The Administration opposed the claim principally by relying upon the Supreme Court’s decision in Union of India v. Ilmo Devi, in which the Supreme Court had considered claims for pay parity by part-time employees. According to the Administration, the principles laid down in that decision prevented the Tribunal from granting the minimum of the regular pay scale to Nanu Ram.

The dispute, however, involved another important dimension. The Administration had already extended the benefit of the minimum pay scale to almost all similarly situated part-time Class-IV employees. Those employees continued to receive the benefit. Nanu Ram was effectively the exception, having approached the Tribunal only after the benefit had been granted to his similarly placed colleagues.

The High Court therefore examined not merely whether a part-time employee could independently claim parity with a regular employee, but also whether an administration which had already extended a particular monetary benefit to a class of similarly situated employees could selectively deny the same benefit to another employee belonging to the same class.

In doing so, the Bench considered the Supreme Court’s decisions in State of Punjab v. Jagjit Singh, Union of India v. Ilmo Devi, Jaggo v. Union of India, Shripal v. Nagar Nigam, Ghaziabad, and Dharam Singh v. State of U.P. The Court also took note of developments concerning the regularisation of long-serving part-time employees.

The judgment ultimately rested on the principle that similarly situated employees should not ordinarily be subjected to different treatment without a legally sustainable distinction. Having extended the minimum pay-scale benefit to almost all comparable part-time Class-IV employees, the Chandigarh Administration could not deny it to Nanu Ram without identifying a valid basis for treating him differently.

Arguments of the Parties:

The Chandigarh Administration challenged the order passed by the Central Administrative Tribunal dated February 3, 2025, which had allowed Nanu Ram’s claim for the minimum of the pay scale attached to the Group-D post on which he had been performing duties.

The Administration contended that the Tribunal had erred in granting the benefit to the respondent merely by relying upon the fact that similarly situated employees had already received it. According to the Administration, the Tribunal ought to have independently examined whether Nanu Ram was legally entitled to the minimum of the regular pay scale.

The principal reliance placed by the Administration was upon the Supreme Court’s judgment in Union of India v. Ilmo Devi, reported in Civil Appeal Nos. 5689-5690 of 2021. The Administration argued that the decision had recognised limitations on the claim of part-time employees seeking parity with regular Group-D employees.

According to the Administration’s interpretation, the fact that some part-time employees had been granted the benefit could not by itself create a legal entitlement in favour of Nanu Ram if the statutory or constitutional principles otherwise did not permit such parity. The Administration submitted that each claim had to be examined on its own legal footing.

The petitioners therefore contended that the Tribunal should not have treated the earlier grant of the benefit to other employees as conclusive. The question whether Nanu Ram was entitled to the minimum of the pay scale, according to the Administration, required an independent determination with reference to the governing law and the Supreme Court’s decision in Ilmo Devi.

The Administration also relied on the distinction between part-time and regular employment. Part-time Class-IV employees worked approximately six hours a day, whereas regular employees worked eight hours. The Administration’s position was that the difference in working hours and nature of engagement could be relevant while determining whether a part-time employee was entitled to the same pay structure as a regular employee.

Nanu Ram, however, supported the Tribunal’s order and contended that the Administration’s own conduct was central to the dispute. He had worked for the Chandigarh Administration for approximately 23 years, performing duties which continued to be required by the Administration. Throughout this period, he had been paid at DC rates.

Counsel for the respondent submitted that the Tribunal had already granted the same benefit to similarly situated part-time Class-IV employees and that those employees continued to receive the minimum of the pay scale. There was therefore no reasonable basis for excluding Nanu Ram from the same benefit.

The respondent’s case was not based merely on an abstract claim for equal pay. It was also founded on the principle of equal treatment among employees belonging to the same class. Once the Administration had accepted that the benefit could be extended to similarly situated part-time Class-IV employees and had actually extended it to almost all of them, it could not arbitrarily select one employee for denial.

The respondent further relied upon the evolving jurisprudence concerning long-serving part-time employees. The High Court noted that it had itself previously directed regularisation of part-time employees of the Chandigarh Administration who had rendered more than two and a half decades of service, and that the direction had subsequently been upheld in light of the Supreme Court’s judgment in Jaggo v. Union of India.

The respondent therefore contended that the legal position concerning long-serving part-time employees could not be viewed solely through the lens of the distinction between part-time and regular employment. The courts had increasingly recognised the need to consider the realities of prolonged service and the continuing nature of the work being performed.

The High Court was consequently required to consider two connected questions. The first was whether the respondent could claim the minimum of the pay scale in light of the Supreme Court’s decisions concerning equal pay and part-time employment. The second was whether the Administration could deny the benefit to him when it had already granted it to almost all employees similarly situated.

The Division Bench considered both questions in the context of the broader development of the law.

Court’s Judgment:

The Punjab and Haryana High Court dismissed the Chandigarh Administration’s petition and upheld the Tribunal’s order granting Nanu Ram the minimum of the pay scale attached to the Group-D post against which he had been working.

The Bench began by examining the circumstances in which part-time Class-IV employees of the Chandigarh Administration had received the benefit of the minimum pay scale. The Court noted that the Administration had extended the benefit to employees working for up to six hours a day.

This extension had taken place in the backdrop of the Supreme Court’s judgment in State of Punjab v. Jagjit Singh. In that decision, the Supreme Court recognised the principle of “equal pay for equal work” and held that temporary employees performing duties similar to those performed by regular employees could, subject to the applicable conditions, be entitled to wages at least equivalent to the minimum of the pay scale applicable to regular employees holding the same post.

The principle in Jagjit Singh was significant because the Court recognised that the mere temporary nature of an employee’s engagement could not automatically justify payment of substantially lower wages where the employee was performing substantially similar duties and responsibilities.

The Chandigarh Administration, however, relied upon the later decision in Union of India v. Ilmo Devi. The High Court carefully examined the effect of that judgment.

In Ilmo Devi, the Supreme Court considered the claim of part-time wage earners who were working for approximately four to five hours a day and had sought parity with regular Group-D employees. The Supreme Court observed that such part-time employees could not ordinarily claim parity with regular Group-D employees merely because they performed some similar duties.

However, the Supreme Court had declined to interfere with the benefit that had already been granted to the employees before it. The continuation of that benefit was influenced by the earlier interim order passed during the proceedings.

The Punjab and Haryana High Court found this aspect particularly relevant to the present dispute. The benefit which had been granted to the similarly situated part-time employees had not subsequently been withdrawn. Instead, the Chandigarh Administration had continued to extend the benefit to similarly placed employees.

The Bench therefore held that the Administration’s reliance on Ilmo Devi could not, in the circumstances of the present case, justify selectively denying the same benefit to Nanu Ram.

The Court emphasised the principle of equal treatment. It observed that similarly situated persons cannot be treated differently without a reasonable basis. Once an employer, particularly a public authority, has extended a benefit to persons belonging to a particular class, it cannot ordinarily deny the same benefit to another person belonging to that class unless there is some valid distinction between them.

The Bench found that “almost all” part-time employees similarly situated to Nanu Ram had already received the benefit. Nanu Ram was essentially the lone employee who had been left out and had therefore approached the Court.

The Court held that the Administration could not adopt one standard for the employees who had already received the benefit and another standard for Nanu Ram without identifying a rational basis for the distinction.

This principle was important because the Administration was not being directed to create an entirely new benefit for Nanu Ram in isolation. Rather, the Court was concerned with the Administration’s selective treatment of an employee who belonged to the same class as those who were already receiving the benefit.

The Bench then considered the development of the law relating to part-time employment and long-serving employees.

The Court noted that it had earlier directed the regularisation of part-time employees of the Chandigarh Administration who had worked for more than two and a half decades. That direction had been upheld in light of the Supreme Court’s decision in Jaggo v. Union of India, SLP(C) No. 5580 of 2024.

The High Court found the Supreme Court’s observations in Jaggo relevant to the broader question. The Supreme Court had cautioned against mechanically applying the principles of Secretary, State of Karnataka v. Uma Devi to deny legitimate claims of employees who had rendered long periods of service. It had also observed that government departments should lead by example in ensuring fair and stable employment conditions.

The High Court therefore considered the respondent’s long period of service relevant to the overall assessment. Nanu Ram had served the Administration for approximately 23 years, and the duties performed by him continued to be required.

The Court reasoned that if part-time service was sufficiently recognised for the purpose of considering regularisation, the fact that the employee worked part-time could not, without further analysis, automatically be used as a reason to deny the minimum of the pay scale, particularly where the Administration had already extended the benefit to similarly situated employees.

This aspect of the judgment reflects the distinction between the legal character of an initial appointment and the subsequent reality of prolonged service. The Court referred to recent Supreme Court decisions in Shripal v. Nagar Nigam, Ghaziabad, Civil Appeal No. 8157 of 2024, decided on January 31, 2025, and Dharam Singh v. State of U.P., Civil Appeal No. 8558 of 2018, decided on August 19, 2025.

The Bench noted that in those cases, the Supreme Court had considered long periods of part-time service in the context of regularisation even where questions existed concerning the initial appointment, the availability of sanctioned posts or the qualifications of the employees concerned.

The High Court treated these developments as relevant to the changing legal understanding of long-serving part-time employment. The Court did not suggest that every part-time employee automatically becomes entitled to all benefits available to a regular employee. Rather, it recognised that the legal consequences of prolonged service must be considered in light of subsequent judicial developments.

The Court consequently rejected the argument that Ilmo Devi, by itself, required the Tribunal’s order to be set aside.

The Bench’s reasoning was particularly influenced by the Administration’s own conduct. The benefit had already been extended to almost all employees belonging to the same category. The Administration continued to allow those employees to receive the benefit. No valid distinction between them and Nanu Ram was demonstrated before the Court.

The principle against arbitrary discrimination therefore became central to the decision.

The High Court observed, in substance, that once the Administration had extended the minimum of the pay scale to similarly situated employees, it could not deny the same benefit to Nanu Ram merely because he happened to be the only employee who approached the Court for the benefit. The fact that an employee had to litigate to obtain a benefit already available to his similarly placed colleagues could not itself become a reason for denying him parity.

The Court also considered the nature of Nanu Ram’s work. The Administration had engaged part-time personnel for Class-IV duties which continued to be required. The difference between the six-hour working schedule of the part-time employees and the eight-hour schedule of regular employees was noted, but the Court did not consider that distinction sufficient, in the circumstances, to justify denying Nanu Ram the minimum of the pay scale that had already been extended to employees similarly situated.

The decision thus did not rest exclusively on the doctrine of equal pay for equal work. It also rested on equal treatment of similarly situated employees, the Administration’s consistent practice of extending the benefit to the class, and the subsequent judicial developments concerning long-serving part-time employees.

The Bench found that there was no ground to interfere with the Tribunal’s order. It therefore upheld the direction granting Nanu Ram the minimum of the pay scale attached to the Group-D post against which he had worked.

The Court’s decision is significant because it illustrates the difference between two related but distinct questions. One question is whether a part-time employee can, as a general proposition, claim parity with a regular employee under the principle of equal pay for equal work. Another is whether a public authority can deny an established benefit to one employee while continuing to grant that very benefit to other employees who are similarly situated.

The second question was decisive in the present case.

The High Court’s reasoning does not mean that every part-time employee will automatically be entitled to the minimum of a regular pay scale. The entitlement depends upon the facts, the nature of the duties, the applicable service rules, the treatment of similarly situated employees and the relevant judicial precedents.

What the Court found impermissible was the Administration’s attempt to maintain the benefit for almost all similarly situated employees while excluding Nanu Ram without establishing a rational distinction.

The judgment also carries significance for long-serving temporary and part-time employees who have continued to perform duties required by government establishments over extended periods. The Court’s reference to Jaggo, Shripal and Dharam Singh demonstrates that the judicial approach to such employment relationships has developed beyond a rigid distinction between regular and non-regular appointments.

At the same time, the judgment remains grounded in the particular facts before the Bench. Nanu Ram had rendered approximately 23 years of service, the Administration continued to require the duties performed by him, similarly situated employees had received the disputed benefit, and no valid distinction was established to justify his exclusion.

The Court ultimately found no ground for denying Nanu Ram at least the minimum of the pay scale and no basis for interfering with the Tribunal’s order.

The petition filed by the Chandigarh Administration was therefore dismissed on August 24, 2026.

The ruling reinforces a fundamental principle of public employment: when a government authority treats employees belonging to the same class in a particular manner, it must have a legally sustainable reason for departing from that treatment in the case of one employee. Administrative discretion cannot become a means of selectively denying an established benefit without a rational basis.

The judgment also places the issue of long-serving part-time employment within the broader constitutional framework of fairness and equality in public employment. While the distinction between part-time and full-time work remains legally relevant, it cannot be applied mechanically where the surrounding circumstances, the employer’s own conduct and subsequent judicial developments point towards equal treatment.

For Nanu Ram, the decision meant that after more than two decades of service, he could not be singled out for denial of a monetary benefit that the Administration had already extended to almost all of his similarly situated colleagues.

The case therefore brings together the principles of equal pay, non-discrimination among similarly situated employees, and the evolving judicial approach towards long-serving part-time workers. The High Court’s refusal to interfere with the Tribunal’s order ultimately rested on the absence of any valid reason for treating Nanu Ram differently from the employees who had already received the benefit.