Supreme Court Upholds Resignation Acceptance in Maharashtra School Teacher Case
The case of Shriram Manohar Bande vs. Uktranti Mandal & Others revolves around the validity of resignation acceptance under the Maharashtra Employees of Private Schools (MEPS) Act and Rules. The Supreme Court examined whether the appellant’s resignation from his teaching position was valid despite his later attempt to withdraw it. The Court ultimately upheld the High Court’s ruling that the resignation was lawfully accepted and that withdrawal after acceptance held no legal ground.
Background of the Case
The appellant was appointed as an Assistant Teacher at Vasantrao Naik High School, a grant-in-aid institution run by Respondent No. 1. On October 10, 2017, he submitted his resignation letter to the School Committee. Later, he claimed to have withdrawn the resignation on October 25, 2017, sending the withdrawal via post on November 3, 2017. However, upon returning to the school on November 23, 2017, he was denied entry and was informed via letter dated November 27, 2017 that he had been relieved from service.
Contesting this, the appellant approached the School Tribunal under Section 9 of the MEPS Act, arguing that his termination was unlawful as he had already withdrawn his resignation before its acceptance. The Tribunal ruled in his favor, ordering his reinstatement with 50% back wages. However, the management challenged this decision in the Bombay High Court, which overturned the Tribunal’s order, holding that the resignation was validly accepted on October 13, 2017, and the appellant’s withdrawal had no legal standing. The appellant then appealed to the Supreme Court.
Key Legal Issues
- Whether the resignation was legally accepted before the withdrawal request.
- Whether the School Committee had the authority to accept the resignation under the MEPS Act and Rules.
- Whether non-communication of resignation acceptance affected its validity.
Arguments by the Appellant
The appellant challenged the High Court’s decision, arguing:
“The resignation was not properly accepted as per the MEPS Act and Rules. The School Committee had no authority to accept it, and I had withdrawn it before any communication of acceptance was made.”
He further contended that the resolution allegedly accepting his resignation on October 13, 2017, was fabricated by the management to justify his termination.
Arguments by the Respondents
The management countered these claims, stating:
“The resignation was voluntarily submitted and properly accepted by the Management Committee. The appellant was informed of the acceptance, and his later withdrawal has no legal standing.”
They further argued that the Tribunal erred in discarding the resolution accepting the resignation as an ‘afterthought’ without sufficient evidence.
Supreme Court’s Analysis
1. Validity of the Resignation Acceptance
The Court examined whether the resignation was validly accepted under Section 7 of the MEPS Act. It ruled:
“A resignation becomes effective upon acceptance, and there is no requirement that the acceptance must be communicated before it becomes operative.”
The Court noted that the resolution dated October 13, 2017, accepting the resignation, was properly recorded and was not fabricated.
2. Authority of the School Committee
The Court clarified that under the MEPS Act and Rules, the School Committee had the authority to process the resignation. It held:
“The School Committee’s function includes employment-related decisions, and in this case, the resignation was duly processed through the correct channels.”
3. Effect of Non-Communication of Acceptance
The Court addressed whether non-communication of acceptance impacted the resignation’s validity, citing North Zone Cultural Centre vs. Vedpathi Dinesh Kumar (2003), where it was held:
“Non-communication of acceptance does not render a resignation ineffective if it has already been accepted.”
The Court ruled that since the appellant’s resignation was formally accepted on October 13, 2017, his withdrawal on October 25, 2017, held no legal weight.
Final Judgment
The Supreme Court upheld the Bombay High Court’s ruling and dismissed the appeal:
“The resignation was validly accepted as per law. The appellant’s claim of withdrawal after acceptance is legally untenable.”
Key Takeaways from the Judgment
- Once a resignation is validly accepted, subsequent withdrawal does not affect its validity.
- The School Committee has the authority to process resignations under the MEPS Act and Rules.
- Non-communication of acceptance does not render a resignation inoperative.
- Courts will not entertain allegations of document fabrication without substantial evidence.
Judgment Date: April 25, 2024
Judges: Pamidighantam Sri Narasimha, Aravind Kumar
Petitioner Name: Shriram Manohar Bande.Respondent Name: Uktranti Mandal & Others.Judgment By: Justice Pamidighantam Sri Narasimha, Justice Aravind Kumar.Place Of Incident: Amravati, Maharashtra.Judgment Date: 25-04-2024.
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