Does an administrative authority have a duty to implement a final Division Bench judgment not stayed by the Supreme Court when deciding identical claims?

Calcutta HC directs respondent to apply its July 4, 2024 Division Bench ruling—uninterfered by the Supreme Court’s November 18, 2024 order—within fixed timelines to determine monetary benefits for retired contractual Gram Panchayat employees; binds such authorities in future writ petitions.

 

Summary

Category Data
Case Name WPA/17767/2025 of DEBABRATA CHAKRABORTY AND ORS. Vs THE STATE OF WEST BENGAL AND ORS.
CNR WBCHCA0362612025
Decision Date 27-08-2025
Disposal Nature DISPOSED
Judgment Author Hon’ble Justice Aniruddha Roy
Court High Court at Calcutta
Bench Single Judge: Aniruddha Roy, J.
Overrules / Affirms Affirms July 4, 2024 Division Bench judgment in MAT 429 of 2024
Type of Law Writ jurisdiction under Article 226 / Administrative Law
Questions of Law Whether respondent no. 3 is bound to follow the Division Bench judgment dated July 4, 2024, not stayed by the Supreme Court, and grant monetary benefits to similarly placed retired contractual employees under the state policy?
Ratio Decidendi The court held that a Division Bench judgment, which has not been stayed or set aside by the Supreme Court, constitutes binding precedent on the appropriate administrative authority when deciding identical claims. Therefore, respondent no. 3 must afford a hearing, consider the Division Bench ruling, and pass a reasoned order within six weeks, implementing any favourable decision within eight weeks.
Judgments Relied Upon
  • Division Bench judgment dated July 4, 2024 in MAT 429 of 2024
  • Supreme Court order dated November 18, 2024
Logic / Jurisprudence / Authorities Relied Upon by the Court Binding nature of Division Bench rulings under Article 226 when not suspended; requirement of reasoned administrative orders after hearing
Facts as Summarised by the Court Petitioners are retired contractual employees of various Gram Panchayats under the Public Health Engineering Department claiming monetary benefits under state policy; they rely on an identical relief granted by a Division Bench judgment which was not interfered with by the Supreme Court.
Citations
  • MAT 429 of 2024 (DB, 04.07.2024)
  • Supreme Court order (18.11.2024)

Practical Impact

Category Impact
Binding On Respondent No. 3 (appropriate administrative authority)
Follows July 4, 2024 Division Bench judgment in MAT 429 of 2024

What’s New / What Lawyers Should Note

  • Administrative authorities are bound to implement final Division Bench judgments not stayed by the Supreme Court when deciding identical claims under writ petitions.
  • Courts can mandate fixed timelines (six weeks for decision; eight weeks for implementation) and require reasoned orders upon hearing.
  • Petitioners can seek similar mandamus relief where previous High Court rulings remain in force despite State non-compliance.
  • The scope of review by the authority is confined to the claims as pleaded in the writ petition.

Summary of Legal Reasoning

  1. Petitioners challenged non-payment of benefits identical to those upheld in a Division Bench judgment dated July 4, 2024 (MAT 429 of 2024), which was not stayed by the Supreme Court’s November 18, 2024 order.
  2. Under Article 226, the High Court has the power to enforce compliance with its own precedents not set aside by higher courts.
  3. Respondent no. 3 is directed to issue a prior-hearing notice, afford petitioners an opportunity to be heard, and pass a reasoned order considering the Division Bench judgment within six weeks.
  4. If the decision is favourable, respondent no. 3 must implement it with all consequential benefits within eight weeks.
  5. The court limited the exercise to the relief sought, clarifying that no rights accrue if the petitioners fail in the administrative proceeding.

Arguments by the Parties

Petitioners

  • Identical claims already upheld in Division Bench judgment (MAT 429 of 2024) which is binding and not stayed by the Supreme Court.
  • Non-compliance with that judgment amounts to denial of relief under state policy.

Respondent

  • No substantive opposition recorded; court directed respondent no. 3 to decide the matter in accordance with law and precedent.

Factual Background

Petitioners are retired contractual employees of various Gram Panchayats under the Public Health Engineering Department who allege entitlement to monetary benefits under a state policy. They filed WPA 17767 of 2025 relying on a Division Bench judgment dated July 4, 2024 in MAT 429 of 2024, which was not stayed by the Supreme Court’s November 18, 2024 order. The High Court directed service on respondent no. 3 and mandated a reasoned decision within specific timelines.

Alert Indicators

  • ✔ Precedent Followed

Citations

  • MAT 429 of 2024 (Calcutta HB DB, 04.07.2024)
  • Supreme Court order dated 18.11.2024 (non-interference with MAT 429 of 2024)

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