The Supreme Court has clarified that
employees cannot claim parity-based relief after a long delay simply because
others in similar positions have secured such benefits, as this would amount to
reopening issues that have already been settled. A bench of Justices Vikram
Nath and Sandeep Mehta emphasized that litigants who notice the success of
others cannot automatically demand similar relief as a matter of right,
particularly when a significant time has passed since the original matter was
resolved.
The case arose from a petition challenging
the State Government’s review under Section 24(4) of the Bombay Primary
Education Act, 1947, which had set aside a tribunal direction for the
reinstatement of the petitioners. The High Court had upheld the state’s
decision, and the Supreme Court in 2014 left it undisturbed. The petitioners
filed the present Special Leave Petition (SLP) relying on a 2021 order of the
Gujarat High Court. In that case, the High Court had directed the competent
authority to consider a representation concerning higher grade pay scales for a
teacher still in service. Although the petitioners were not parties to that
case, they sought the same relief, arguing that the benefit granted in the 2021
order should apply to them as well.
The Supreme Court dismissed the plea,
noting that the matter concerning the appellants was already conclusively
settled, and it was not open to them to revive the same issue after such a long
delay. The bench explained that courts and tribunals must first determine
whether a claim relates to a live issue before issuing directions for
consideration without examining merits. If a claim pertains to a stale or
concluded matter, the court must refuse to entertain it, rather than allowing
successive rounds of litigation that are avoidable.
The Court further clarified that while
relief granted to one set of individuals can, in certain circumstances, be
extended to others who are identically situated, such extensions are subject to
recognized exceptions, including delay, laches, and acquiescence, as laid down
in State of Uttar Pradesh v. Arvind Kumar Srivastava (2015) 1 SCC 347. In the
instant case, the petitioners were not in a position identical to the
individuals involved in the Gujarat High Court’s 2021 order, and therefore
could not claim the same benefit.
In addition, the Supreme Court advised
counsel to discourage clients from pursuing claims based on subsequent
developments or orders granted to others, particularly when the original issues
have attained finality. The Court emphasized the importance of preserving
judicial resources and maintaining the principle of finality in legal
proceedings. Counsel is expected to assist courts by presenting complete
procedural histories, highlighting orders that have become final, and drawing
attention to binding precedents regarding delay, laches, and maintainability.
The bench warned that allowing repetitive proceedings that seek to reopen
concluded disputes undermines the efficiency and discipline of the justice
delivery system.
By dismissing the petition, the Supreme
Court reaffirmed that long-delayed attempts to secure parity-based relief
cannot override settled law and stressed the necessity of finality in
litigation to prevent avoidable litigation and protect judicial time.