Field Supervisor as Teacher: Supreme Court Upholds University Decision

The case of Registrar, Orissa University of Agriculture & Technology vs. Upendra Nath Patra & Anr. revolves around the classification of Field Supervisors as Teachers under the Orissa University of Agriculture and Technology Act, 1965. The Supreme Court had to decide whether the High Court was justified in holding that Field Supervisors should be treated as Teachers and entitled to corresponding benefits.

The appellant, Orissa University of Agriculture & Technology (OUAT), challenged the decision of the Orissa High Court, which ruled that Field Supervisors should be treated as Teachers for service and pay benefits. The Supreme Court upheld the decision, ensuring that the respondents would receive all the benefits they were entitled to.

Background of the Case

The dispute arose when Upendra Nath Patra and Binod Chandra Mahanti, appointed as Field Supervisors at OUAT, sought recognition as Teachers under Statute 19(1) of the University’s statutes. Patra filed OJC No. 2412 of 1985, which was allowed by the High Court, holding that Field Supervisors were equivalent to Teachers. However, in a similar case (OJC No. 3390 of 1990), the High Court ruled otherwise, creating a conflict.

The Full Bench of the High Court resolved the conflict by upholding the earlier ruling in favor of the Field Supervisors. The University challenged this ruling before the Supreme Court.

Arguments by the Parties

Petitioner’s Arguments (Orissa University of Agriculture & Technology)

The University contended that:

• Field Supervisors were not appointed for teaching purposes and did not fall under the statutory definition of Teachers.
• Statute 19(3) required that equivalence to a Teacher’s post be declared by the University with prior approval from the Board.
• The earlier decision of the High Court had misinterpreted the scope of the statutory provisions.

Respondents’ Arguments (Upendra Nath Patra & Binod Chandra Mahanti)

The respondents argued that:

• The University had, in its communication dated March 26, 1981, acknowledged Field Supervisors as Teachers.
• The Registrar’s office had issued an order treating Field Supervisors as Teachers for electoral purposes, which should apply to service conditions as well.
• The University’s contention that no such recognition had been granted was misleading and contradicted its own records.

Supreme Court’s Analysis

The Supreme Court reviewed the provisions of the Orissa University of Agriculture and Technology Act, 1965:

• Section 2(10) defines a Teacher as a person appointed to impart instruction, conduct research, or guide extension programs.
• Statute 19(1) classifies Teachers into three categories—those imparting education, those conducting research, and those declared as Teachers by the University.
• Statute 19(3) allows the University to declare a post equivalent to a teaching post with prior Board approval.

The Court found that the University had already classified Field Supervisors as Teachers for electoral purposes and had not withdrawn that status. It ruled that this classification should apply uniformly across service benefits.

Key Observations by the Court

The Supreme Court ruled:

“Once a post is recognized as a Teacher’s post for one purpose, it cannot be denied for others. The University cannot selectively apply its own classifications.”

Final Judgment

The Supreme Court dismissed the appeal and upheld the High Court’s ruling. It ruled:

“The respondents are entitled to all benefits of being recognized as Teachers. The University may withdraw the earlier declaration prospectively but cannot deny benefits already accrued.”

Conclusion

This case reaffirms the principle that classification decisions by a public institution must be applied consistently. The ruling ensures that individuals classified as Teachers for one purpose cannot be arbitrarily denied the same status for service benefits.

Petitioner Name: Registrar, Orissa University of Agriculture & Technology.
Respondent Name: Upendra Nath Patra & Anr..
Judgment By: Justice S.A. Bobde, Justice L. Nageswara Rao.
Place Of Incident: Orissa.
Judgment Date: 23-04-2018.

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