Geeta Mishra vs. Sidho Kanhu Murmu University: Supreme Court Ruling on Pension Scheme Eligibility

The case of Geeta Mishra vs. Sidho Kanhu Murmu University & Others revolves around the eligibility for exercising a fresh option under the pension scheme floated by the university. The legal battle began when the appellant, Geeta Mishra, sought benefits under a revised pension scheme after her husband’s demise. The Supreme Court upheld the High Court’s decision, ruling against her eligibility.

Background of the Case

Geeta Mishra’s husband was a Lecturer in the Department of Chemistry at Godda College under Sidho Kanhu Murmu University. He was later promoted to the position of Reader. He had opted for the Contributory Provident Fund (CPF) scheme during his service tenure, and contributions were deducted from his salary accordingly. Unfortunately, he passed away while in service on February 24, 1995.

After his demise, his family received all the retiral benefits as per his selected scheme. However, in 1998, the university introduced a new pension scheme allowing employees who retired on or after April 1, 1972, but had not exercised their option before death, to allow their family members to exercise a fresh option. Geeta Mishra applied under this scheme to opt for pension benefits instead of the CPF scheme.

Legal Proceedings

Initially, a Single Judge Bench ruled in favor of Geeta Mishra, interpreting the scheme to allow her to exercise a fresh option for pension benefits. However, the university challenged this ruling in a Letters Patent Appeal (LPA), and the Division Bench of the Jharkhand High Court set aside the Single Judge’s order, ruling that she was not entitled to exercise the fresh option as her husband had already opted for the CPF scheme before his death.

Dissatisfied with the High Court’s decision, Geeta Mishra filed an appeal before the Supreme Court.

Arguments by the Petitioner (Geeta Mishra)

The petitioner argued that the university’s scheme allowed family members to exercise a fresh option if the employee had died before opting for the pension scheme.
She contended that the High Court’s interpretation was incorrect and restrictive, denying her a benefit that similarly placed individuals had received.
She cited previous judgments where other petitioners were granted the benefit of a fresh option under similar circumstances.

Arguments by the Respondents (Sidho Kanhu Murmu University)

The university argued that the scheme was only applicable to employees who had died before exercising any option, whereas the petitioner’s husband had already chosen the CPF scheme during his service.
It was contended that since all benefits under the CPF scheme had been duly paid, allowing a fresh option would create inconsistencies in financial planning.
The respondents further emphasized that the conditions in Clause 5 of the scheme specifically limited eligibility to those who had not opted for any scheme before their demise.

Supreme Court’s Judgment

The Supreme Court bench, comprising Indira Banerjee and J.K. Maheshwari, upheld the High Court’s ruling, stating:

“The condition No. 5 of the Scheme clearly spelt out that an employee, who retired from the service of the University on or after 1.4.1972, but had died before exercising his/her option, then his/her family shall be eligible for exercising the fresh option, giving them one more chance subject to the terms and conditions.”

The Court further observed:

“In the present case, it is not disputed that the husband of the appellant had already exercised the option prior to his death. All the benefits in terms of the option so exercised under the prevalent Scheme have been received by the family members. In the said contingency, as per the terms and conditions of the Scheme, the appellant did not have the right to exercise a fresh option.”

The Supreme Court concluded that the Division Bench had correctly interpreted Clause 5 of the Scheme and dismissed Geeta Mishra’s appeal.

Implications of the Judgment

The Supreme Court’s decision has significant implications for pension and provident fund schemes in government institutions:

Clarification on eligibility: The ruling establishes that pension schemes allowing a “fresh option” only apply to employees who had not made any prior selection.
Finality of choices in employment benefits: Once an employee selects a retirement benefits scheme, their family cannot later opt for a different scheme.
Precedent for similar cases: The judgment sets a binding precedent for future cases involving pension schemes with multiple options.

Conclusion

The Supreme Court’s ruling in Geeta Mishra vs. Sidho Kanhu Murmu University & Others reaffirms that employment benefits, once opted for, cannot be altered posthumously by family members. The decision ensures consistency in pension administration and upholds the principle that financial schemes must be followed as per their stipulated terms and conditions.

Petitioner Name: Geeta Mishra.
Respondent Name: Sidho Kanhu Murmu University & Others.
Judgment By: Justice Indira Banerjee, Justice J.K. Maheshwari.
Place Of Incident: Jharkhand.
Judgment Date: 16-11-2021.

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