Supreme Court Clarifies MACP Scheme Benefits and Limitation Rules in Service Dispute

The Supreme Court of India recently delivered a significant judgment in the case of The Chief Executive Officer & Others versus S. Laltha & Others, addressing crucial issues regarding the Modified Assured Career Progression (MACP) Scheme and the limitation period for filing service-related claims. The judgment, dated April 24, 2025, provides clarity on the interpretation of financial upgradation benefits under the MACP Scheme and the importance of timely legal recourse in service disputes.

The case revolved around the respondent, S. Laltha, who joined Doordarshan Kendra, Bangalore, in 1985 and received financial upgradations under both the Assured Career Progression (ACP) Scheme and the MACP Scheme. While she initially accepted these benefits without objection, she later claimed entitlement to higher benefits under the ACP Scheme, filing a representation in 2016, which was rejected. She then approached the Central Administrative Tribunal (CAT), which ruled in her favor, a decision later affirmed by the High Court. The appellants, challenging these rulings, argued that the respondent’s claim was time-barred and that the MACP Scheme’s provisions had been correctly applied.

The Supreme Court, in its judgment, emphasized the critical distinction between the ACP and MACP Schemes. The Court noted, “The basic difference between the ACP Scheme and the MACP Scheme appears to be that while under the former scheme the financial upgradation was to the pay scale of the next higher promotional post in the service, under the latter scheme, financial upgradation was with reference to the next higher grade pay in the scale of pay.” This clarification was pivotal in understanding the respondent’s entitlements.

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The Court also addressed the issue of limitation, ruling that the respondent’s belated representation in 2016 did not revive her claim, which had become stale due to her earlier acceptance of the MACP benefits. The Court observed, “The cause of action cannot be deferred by making a highly belated representation and awaiting its outcome.” Despite this, the Court refrained from ordering the recovery of any excess amounts paid to the respondent, considering her retirement and the need for financial stability in her later years.

This judgment underscores the importance of adhering to statutory timelines in service disputes and provides valuable guidance on the interpretation of career progression schemes for government employees. It balances legal principles with humanitarian considerations, ensuring justice while acknowledging the practical realities faced by retirees.

Petitioner Name: The Chief Executive Officer & Others.
Respondent Name: S. Laltha & Others.
Judgment By: Justice Dipankar Datta, Justice Rajesh Bindal.
Place Of Incident: Doordarshan Kendra, Bangalore.
Judgment Date: 24-04-2025.
Result: dismissed.

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