Featured image for Supreme Court Judgment dated 02-07-2018 in case of petitioner name Director General, CRPF & Ors. vs Janardan Singh & Ors.
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CRPF Personnel Entitled to Special Duty Allowance: Supreme Court Upholds Tribunal’s Order

The Supreme Court of India, in Director General, CRPF & Ors. vs. Janardan Singh & Ors., upheld the Central Administrative Tribunal’s decision, ensuring that CRPF personnel deployed in the North Eastern Region (NER) were entitled to Special Duty Allowance (SDA), irrespective of the location of their headquarters. The judgment dismissed the government’s appeal and reinforced the principle of fair compensation for personnel serving in challenging regions.

Background of the Case

The case stemmed from a long-standing dispute over the eligibility of CRPF personnel for Special Duty Allowance. The government had initially granted the allowance to employees whose headquarters were in the NER but denied it to those deployed in the region with headquarters elsewhere.

The respondents, who were CRPF pharmacists, filed a claim stating that they were posted in NER and, therefore, should receive SDA as per the government’s 1983 and 1986 Office Memorandums (OMs). Their claim was rejected, leading them to approach the Central Administrative Tribunal (CAT), which ruled in their favor.

The government challenged this decision in the Allahabad High Court, which upheld the CAT’s ruling. The government then appealed to the Supreme Court.

Petitioner’s Arguments

The government contended:

  • The respondents were not entitled to SDA before August 3, 2005, as their headquarters were outside the NER.
  • The policy initially limited SDA to personnel whose headquarters were within the NER.
  • The August 3, 2005, OM clarified that all CRPF personnel deployed in NER were eligible, but this should not apply retrospectively.

Respondent’s Arguments

The respondents countered:

  • The SDA policy was intended to compensate personnel working in difficult conditions, regardless of headquarters location.
  • The August 3, 2005, OM was clarificatory and did not create a new entitlement.
  • Denying SDA based on headquarters location was discriminatory and violated Article 14 of the Constitution.

Supreme Court’s Key Observations

The Supreme Court examined the purpose of SDA and stated:

“The purpose and object of granting Special Duty Allowance was to encourage, attract, and retain competent officers in the North Eastern Region. Denying this benefit solely based on the location of headquarters lacks any intelligible differentia and fails the test of reasonable classification.”

The Court held that the August 3, 2005, OM was a clarification, not a new policy, and ruled that SDA should be granted to all CRPF personnel deployed in NER for the entire duration of their posting.

Final Judgment and Conclusion

The Supreme Court ruled:

  • The government’s appeal was dismissed.
  • CRPF personnel posted in NER were entitled to SDA from the date of their posting, not just from August 3, 2005.
  • The denial of SDA based on headquarters location was unconstitutional.

This landmark judgment reinforces fair treatment of government employees and upholds their rights to allowances designed to compensate for service in challenging conditions. The ruling ensures equitable benefits for personnel serving in the North Eastern Region.


Petitioner Name: Director General, CRPF & Ors..
Respondent Name: Janardan Singh & Ors..
Judgment By: Justice Adarsh Kumar Goel, Justice Ashok Bhushan.
Place Of Incident: North Eastern Region, India.
Judgment Date: 02-07-2018.

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