Supreme Court Orders Reinstatement of Employee in PFRDA Appointment Dispute

The case of Mamta Rohit v. Dr. Prafulla Ranjan & Ors. centers around an employment dispute regarding the appointment of the appellant, Mamta Rohit, to the post of Chief General Manager under the Pension Fund Regulatory and Development Authority (PFRDA). The Supreme Court was called upon to determine whether the cancellation of her appointment on the grounds of qualification criteria was justified after she had already served in the position for years.

Background of the Case

In 2011, PFRDA invited applications for two posts of Chief General Manager. The appellant, Mamta Rohit, applied for the post and was eventually selected based on a written test and an interview. The selection process was overseen by the Board of Directors, which included a nominee from the Government of India.

Before taking up the appointment, Mamta Rohit resigned from her position as Deputy General Manager at IDBI Bank. She subsequently joined PFRDA on 01.07.2011 and completed her probation period successfully. She was later confirmed in her position and even received two annual increments.

The Dispute Arises

Towards the end of 2013, certain unsuccessful candidates challenged her appointment before the Central Administrative Tribunal (CAT), arguing that she did not meet the necessary qualifications for the position. Meanwhile, the Ministry of Finance issued a letter on 17.02.2014, prompting PFRDA to issue a Show Cause Notice to Mamta Rohit on 21.02.2014. Not satisfied with her reply, the authorities canceled her appointment on 13.03.2014.

Aggrieved by this decision, Mamta Rohit approached CAT at Allahabad, challenging her termination. Due to an interim order, she continued in service until the Delhi High Court set aside the CAT order and upheld her removal in 2017.

Legal Issues

Was the relaxation of qualification criteria in Mamta Rohit’s appointment valid?
Did PFRDA have the authority to retrospectively cancel her appointment after confirming her in service?
Was the High Court justified in setting aside CAT’s decision?

Arguments by the Appellant

Mamta Rohit contended that:

She had applied for the post in good faith and was selected based on merit.
The Board of Directors, including the Government of India’s nominee, found her suitable for the position.
She had already resigned from her previous job and served PFRDA for a significant period before her appointment was questioned.
Her appointment was confirmed, and she had received annual increments.
The retrospective cancellation of her appointment caused undue hardship and violated the principles of natural justice.

Arguments by the Respondents

The respondents, including the unsuccessful candidates and PFRDA, argued that:

She did not meet the prescribed qualification criteria at the time of application.
Although the appointing authority had the power to relax criteria, such relaxation must be done on a case-to-case basis and should not be assumed as automatic.
The High Court correctly held that there could not be a “deemed relaxation” of qualifications.
Her appointment was void ab initio (invalid from the beginning) as she was ineligible for the post.

Supreme Court’s Observations

The Supreme Court carefully analyzed the issue and held that while the respondents’ argument regarding qualification relaxation was legally sound, the cancellation of Mamta Rohit’s appointment was unfair given the unique facts of the case.

The Court noted:

“The High Court has rightly held on the question of law that there cannot be a deemed relaxation since on the very concept of relaxation, it is to be made on the basis of proper application of mind as to whether it was a case fit for relaxation.”

However, the Court also pointed out:

“The appellant was made to resign from her post in IDBI Bank to take up this appointment. She was found suitable for the post and confirmed in service. Two annual increments were sanctioned, and thereafter, action was taken to terminate her appointment.”

Final Verdict

The Supreme Court ruled in favor of Mamta Rohit, stating that given the circumstances, justice demanded that her appointment be restored.

The Court ordered:

The cancellation of her appointment on 13.03.2014 was set aside.
She must be reinstated in service forthwith.
Her service shall be deemed continuous from 01.10.2018 onwards.
Her employment history shall be treated as unbroken for all purposes, except for actual back wages.

However, the Court clarified:

“This judgment is passed in the peculiar facts and circumstances of the case and shall not be treated as a precedent.”

Conclusion

This case highlights the complexities involved in employment disputes, especially when appointments are challenged based on qualification criteria. The Supreme Court struck a balance between upholding the legal principle that relaxations in eligibility criteria must be explicit and ensuring that an individual was not unfairly penalized after serving in a position for years. The ruling reinforces the importance of fairness in employment decisions and protects employees from arbitrary removals.

Petitioner Name: Mamta Rohit.
Respondent Name: Dr. Prafulla Ranjan & Ors..
Judgment By: Justice Kurian Joseph, Justice Sanjay Kishan Kaul.
Place Of Incident: New Delhi.
Judgment Date: 26-09-2018.

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