Supreme Court Rules on Career Advancement Scheme for Rajasthan Agricultural University Professors

The case of Rajasthan Agricultural University, Bikaner v. Dr. Zabar Singh Solanki & Ors. revolves around the dispute regarding the eligibility of Research Assistants who were redesignated as Assistant Professors for benefits under the Career Advancement Scheme (CAS). The Supreme Court was called upon to decide whether these employees, whose designation was changed without direct appointment, could be entitled to the same benefits as those who were appointed through a regular selection process. The Court ruled against the respondents, stating that re-designation does not amount to regular appointment and that CAS benefits apply only to those recruited directly as Assistant Professors.

The dispute originated when Rajasthan Agricultural University, following government orders and University Grants Commission (UGC) recommendations, revised its pay scale structure and allowed Research Assistants to be re-designated as Assistant Professors. However, later objections were raised regarding their eligibility for CAS benefits, leading to a legal battle that eventually reached the Supreme Court.

Background of the Case

Facts Leading to the Dispute

Respondents were originally appointed as Research Assistants at the Rajasthan Agricultural University.
In 1977, they were redesignated as Lecturers and later as Assistant Professors.
The Government of India introduced the Career Advancement Scheme (CAS) in 1988, offering promotions based on years of service.
The university extended CAS benefits to these redesignated Assistant Professors.
The State Government of Rajasthan objected, stating that CAS benefits should be given only to those directly appointed as Assistant Professors.
Following the state government’s direction, the university withdrew the CAS benefits, leading to legal challenges by the affected employees.
The Rajasthan High Court ruled in favor of the employees, stating that since they were redesignated as Assistant Professors, they were entitled to CAS benefits.
The university appealed against this ruling to the Supreme Court.

Legal Issues Raised

Appellants’ Arguments

The university contended that:

The respondents were never directly appointed as Assistant Professors through a regular selection process.
Re-designation does not amount to regular appointment and should not grant eligibility for CAS benefits.
The Career Advancement Scheme explicitly required eight years of service after direct appointment.
The Rajasthan Universities Teachers and Officers (Selection for Appointment) Act, 1974, distinguishes between directly recruited Assistant Professors and those promoted through internal procedures.
The High Court failed to consider that a previous Supreme Court ruling had already clarified that Research Assistants and Assistant Professors belong to distinct cadres.

Respondents’ Arguments

The employees who were redesignated as Assistant Professors argued that:

Their re-designation was approved by the university and recognized in multiple official communications.
Their work responsibilities and pay scales were the same as those of direct appointees.
Once they were re-designated as Assistant Professors, they should be treated on par with those who were directly recruited.
The government’s decision to withdraw CAS benefits was arbitrary and violated their legitimate expectations.
The High Court correctly ruled in their favor by recognizing that redesignation was functionally equivalent to direct appointment.

Supreme Court’s Observations

On the Meaning of Regular Appointment

The Supreme Court emphasized that:

The term “regular appointment” in CAS rules refers exclusively to direct recruitment through a proper selection process.
Re-designation of an existing employee to a different position does not satisfy the requirement of direct appointment.
The Rajasthan Universities Act, 1974, mandates that Assistant Professors be appointed through a statutory selection committee.

On the Distinction Between Re-designation and Appointment

The Court clarified that:

Re-designation only changes the title of the position but does not confer additional rights equivalent to direct recruitment.
Pay parity does not automatically equate to eligibility for promotional benefits under CAS.
The university’s initial decision to grant CAS benefits was made without proper legal scrutiny and was rightly corrected later.

Legal Precedents Considered

The Court referred to several landmark judgments, including:

State of Maharashtra v. Tara Ashwin Patel (2016) – Held that upgradation of a post does not equate to direct appointment.
State of Rajasthan v. Milap Chand Jain (2013) – Reaffirmed that service conditions must be applied strictly as per government policy.
University Grants Commission v. Neha Mathur (2020) – Clarified that CAS benefits are tied to specific eligibility conditions, including direct recruitment.

Final Judgment

The Supreme Court ruled that:

The Rajasthan High Court’s judgment was set aside.
The respondents were not entitled to CAS benefits as they were not directly appointed as Assistant Professors.
The decision of the State Government of Rajasthan to withdraw CAS benefits was valid.
No recovery would be made from respondents for past benefits already received.
Future promotions and pay benefits would be calculated based on their actual recruitment status, not on their re-designation.

This ruling reinforces the principle that government employment schemes must be interpreted strictly according to their stated eligibility conditions. It ensures that promotional benefits like CAS remain reserved for those who meet the prescribed recruitment criteria.

Petitioner Name: Rajasthan Agricultural University, Bikaner.
Respondent Name: Dr. Zabar Singh Solanki & Ors..
Judgment By: Justice Hima Kohli, Justice Ahsanuddin Amanullah.
Place Of Incident: Rajasthan.
Judgment Date: 05-08-2024.

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