Supreme Court Directs Fact-Finding Inquiry in Magadh University Salary and Pension Dispute
The Supreme Court of India has recently disposed of a long-pending contempt petition in the case of Dr. Shyam Narayan Singh & Others vs. Sanjay Kumar & Others. The petitioners, who were faculty members of Magadh University, alleged non-compliance with previous court orders regarding their salary arrears and pension payments. The Court directed a fact-finding inquiry to determine their actual working periods and rightful entitlements.
Background of the Case
The dispute originated from the absorption of teaching staff in various colleges affiliated with Magadh University. Their absorption was validated by the Justice S.B. Sinha Commission (J. Sinha Commission), which passed orders confirming their employment status. The Supreme Court, in an earlier ruling on August 31, 2017, upheld these absorptions, provided that each petitioner submitted a declaration confirming their continuous service.
Despite this ruling, several faculty members claimed that their arrears of salary and pensions had not been released. They approached the Supreme Court, arguing that Magadh University and the State of Bihar had failed to comply with the court’s directives.
Legal Issues Raised
The petitioners contended that:
- Magadh University had not processed their pension benefits despite their absorption being validated.
- Salary arrears were withheld due to administrative delays and objections from the State of Bihar.
- The orders dated July 11, 2019, and August 7, 2019, had led to an unjust stoppage of pension payments.
- The University failed to verify their continuous service records in a fair manner.
The respondents, including the State of Bihar and Magadh University, argued:
- All regular salaries had been paid as per the court’s directive of January 14, 2020.
- Pension and arrears were withheld due to previous Supreme Court orders preventing payments for non-working periods.
- A fact-finding inquiry was necessary to verify the actual working periods of the petitioners before disbursing further payments.
Supreme Court’s Observations
The Court recognized that while regular salaries were paid, pension payments and salary arrears remained unresolved due to previous contempt proceedings. It acknowledged that a detailed verification process was needed to determine the eligibility of each petitioner.
1. Fact-Finding Inquiry
The Court emphasized the need for an inquiry to establish the legitimacy of the claims:
“The issue regarding actual working of the individual petitioner, payment of salary, and arrears thereof requires adjudication after fact-finding enquiry which we are not inclined to hold in this contempt petition.”
2. Clarification on Pension Payments
The Court ruled that the orders of July 11, 2019, and August 7, 2019, did not explicitly prohibit pension payments. It noted:
“It is not reported that after affording opportunity, an enquiry has been completed. However, we do not deem it appropriate to keep these matters pending.”
3. Direction for Resolution
The Court directed the Registrar/Vice Chancellor of Magadh University to conduct the necessary fact-finding inquiry and resolve the pending issues:
“The authorities shall adjudicate all the said issues through the Registrar/Vice Chancellor.”
Final Directions
The Supreme Court laid down specific steps for resolving the dispute:
- The petitioners must submit their claims regarding actual working periods, salary arrears, and pension entitlements before the Registrar/Vice Chancellor of Magadh University by February 28, 2025.
- The University shall conduct a discrete inquiry with input from the college concerned, the employee, and, if necessary, the State Government.
- A reasoned order regarding the payment of salary arrears shall be passed within three months of receiving the claims.
- Pension eligibility shall be determined independently of the previous Supreme Court orders preventing salary disbursement for non-working periods.
- All eligible pension amounts and arrears shall be paid within two months of the inquiry’s conclusion.
- If any excess payments were made earlier, the University and the State Government shall have the right to recover them through proper procedures.
- If any party is dissatisfied with the decision of the Registrar/Vice Chancellor, they may seek legal recourse before the High Court.
Conclusion
This ruling underscores the Supreme Court’s approach to balancing legal compliance with equitable relief. By directing a fact-finding inquiry rather than passing a direct contempt ruling, the Court ensured that all claims are verified through due process. The judgment provides clarity on pension entitlements while reaffirming the importance of verifying salary arrears based on actual service records.
Petitioner Name: Dr. Shyam Narayan Singh & Others.
Respondent Name: Sanjay Kumar & Others.
Judgment By: Justice J.K. Maheshwari, Justice Rajesh Bindal.
Place Of Incident: Bihar.
Judgment Date: 08-01-2025.
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