The Madras High Court has clarified that Vocational Instructors are not entitled to benefits under Additional Fitment Table 15 unless there is an elevation from one pay band to another, strictly adhering to policy set forth in the government orders and rejecting linkage with Rule 4(1)(iii) of the Tamil Nadu Revised Scale of Pay Rules, 2009. This decision upholds existing precedent and is binding on subordinate courts within Tamil Nadu, impacting pay-fixation disputes in the education sector.
Summary
| Category | Data |
|---|---|
| Case Name | WA(MD)/2699/2025 of The Principal Secretary to the Government, Vs K.Loganathan |
| CNR | HCMD010527092025 |
| Date of Registration | 15-09-2025 |
| Decision Date | 15-10-2025 |
| Disposal Nature | ALLOWED |
| Judgment Author | Dr. Justice Anita Sumanth |
| Concurring or Dissenting Judges | Mr. Justice C.Kumarappan |
| Court | Madras High Court |
| Bench | Honourable Dr. Justice Anita Sumanth and Honourable Mr. Justice C.Kumarappan |
| Precedent Value | Binding on subordinate courts in Tamil Nadu |
| Overrules / Affirms | Affirms the order in W.A.(MD)No.468 of 2025 and W.A.(MD)No.2567 of 2025 |
| Type of Law | Service Law / Pay Fixation under Tamil Nadu Revised Scale of Pay Rules, 2009 |
| Questions of Law | Whether Additional Fitment Table 15 can be invoked for Vocational Instructors where there is no upgradation from one pay band to another |
| Ratio Decidendi |
The Court held that Additional Fitment Table 15 is not applicable to Vocational Instructors unless their pay band has been upgraded from one level to another due to the implementation of One Man Commission recommendations. There is no logical or legal basis to link Rule 4(1)(iii) of the 2009 Rules with the Additional Fitment Tables. Pay-fixation matters involving large financial implications are policy matters for the government, not for writ courts. The revision that occurred was solely in grade pay, not in the pay band. Therefore, the Single Judge’s contrary view was set aside. Changes in grade pay alone, without upward migration of pay band, cannot attract Additional Fitment Table 15. |
| Judgments Relied Upon |
|
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
|
| Facts as Summarised by the Court |
Vocational Instructors challenged pay-fixation, seeking applicability of Additional Fitment Table 15. The government revised only the grade pay, not the pay band. Previous decisions, government orders, and recommendations addressed anomalies in grade pay for Vocational Instructors of different grades. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Tamil Nadu |
| Persuasive For | Other High Courts considering similar pay-fixation issues in public employment/service law |
| Follows |
|
What’s New / What Lawyers Should Note
- Reiterates that mere revision of grade pay, without upgradation in pay band, does not entitle employees to benefits under Additional Fitment Table 15.
- Explicitly separates the application of Rule 4(1)(iii) of the Tamil Nadu Revised Scale of Pay Rules, 2009 from the eligibility conditions of Additional Fitment Tables notified under government letters.
- Places pay-fixation policy and its administrative burden beyond the scope of writ court adjudication.
- Offers authoritative guidance for counsel appearing in service matters on the strict prerequisites for invoking additional fitment benefits.
Summary of Legal Reasoning
The Court, referencing its earlier decisions in W.A.(MD)No.468 of 2025 and W.A.(MD)No.2567 of 2025, held that Additional Fitment Table 15 is only applicable where the pay band of the post in question has been elevated as a result of government policy, specifically the recommendations of the One Man Commission.
The Court found that, for Vocational Instructors, only the grade pay was revised, not the pay band, and rejected the Single Judge’s approach of linking Rule 4(1)(iii) with the eligibility for additional fitment tables, emphasizing that there was no statutory or policy basis for such linkage.
The Court also highlighted that significant pay-fixation decisions with financial implications are matters of executive policy and not justiciable via writ courts. Prior anomalies affecting vocational instructors had already been addressed by the government through a series of orders, and further application of additional fitment benefits was not warranted absent policy-justified pay band elevation.
Arguments by the Parties
Petitioner (Appellants – State/Government):
- The issue is covered by prior division bench orders (W.A.(MD)No.468/2025 and W.A.(MD)No.2567/2025), both favoring the State.
- Additional Fitment Table 15 applies only if the pay band of the post has been elevated per One Man Commission recommendations, which is not the case for Vocational Instructors.
- Linking Rule 4(1)(iii) to the additional fitment tables lacks basis.
- Pay-fixation issues are policy matters due to their large financial implications.
- The anomalies in selection/special grade have already been redressed through government orders.
Respondent:
No appearance by the respondent.
Factual Background
The writ appeal arose from disputes regarding pay fixation for Vocational Instructors in Tamil Nadu, centering on whether they were entitled to the benefits of Additional Fitment Table 15 after the implementation of revised pay scales under the One Man Commission recommendations. The government had only revised the grade pay for Vocational Instructors via various government orders, without elevating their pay band. Prior government orders had addressed pay anomalies for selection and special grade Vocational Instructors, and the present matter involved the State contesting a Single Judge’s order granting additional fitment benefits in the absence of a pay band upgrade.
Statutory Analysis
The Court considered Rule 4(1)(ii) and Rule 4(1)(iii) of the Tamil Nadu Revised Scale of Pay Rules, 2009, determining that the application of Additional Fitment Table 15 requires elevation of pay band, not merely an increase in grade pay. The Additional Fitment Table was treated as operative only upon fulfillment of a pay band upgradation condition as per government policy. The Court clarified that there is no logical or legal basis to link Rule 4(1)(iii) with the Additional Fitment Tables annexed to government communications dated 15.09.2010.
Dissenting / Concurring Opinion Summary
There was no dissenting or concurring opinion. Both judges concurred in the reasoning and outcome.
Procedural Innovations
No new procedural innovations were introduced or discussed in this judgment.
Alert Indicators
- ✔ Precedent Followed – The decision affirms, follows, and applies the precedent set in W.A.(MD)No.468 of 2025 and W.A.(MD)No.2567 of 2025, maintaining legal continuity in pay-fixation jurisprudence for public servants in Tamil Nadu.