Does proviso (ii) of Rule 271 and proviso (4) of Rule 272 of the Uttarakhand Cooperative Societies Rules, 2004 apply to members reappointed post-superannuation for pension and gratuity revision?

The High Court reaffirmed that the plain language of these provisos covers all members retiring from the Cooperative Tribunal—including those reappointed post-superannuation—thereby providing binding authority for recalculation of pension and other retiral benefits under service law.

 

Summary

Category Data
Case Name WPSB/259/2019 of TARKENDRA VAISHNAV Vs STATE OF UTTARAKHAND
CNR UKHC010096092019
Date of Registration 27-06-2019
Decision Date 25-08-2025
Disposal Nature ALLOWED
Judgment Author Hon’ble Mr. Justice Alok Mahra
Concurring Judge Hon’ble Mr. Justice Ravindra Maithani
Court High Court of Uttarakhand at Nainital
Bench Division Bench
Precedent Value Binding
Overrules / Affirms Affirms
Type of Law Service Law
Questions of Law
  • Interpretation of proviso (ii) to Rule 271 and proviso (4) to Rule 272 of the Uttarakhand Cooperative Societies Rules, 2004 regarding entitlement to revised pension and gratuity for members reappointed post-superannuation
Ratio Decidendi

The plain wording of proviso (ii) of Rule 271 and proviso (4) of Rule 272 entitles any person retiring from the post of Chairman or Member of the Tribunal—including those reappointed after superannuation—to recalculated pension, gratuity and leave encashment.

The court rejected the State’s narrow interpretation, held the rules pari materia with the UP Cooperative Societies Rules, and directed recalculation of benefits within 12 weeks for the period served as Tribunal members.

Logic / Authorities Relied Upon Plain-text interpretation of the relevant provisos in the statutory rules
Facts as Summarised by the Court

Petitioners superannuated in 2008 and 2010 from their parent services, were appointed as Members of the Uttarakhand Cooperative Tribunal in 2010 and 2011, served until age 66, and sought revision of pension and gratuity under Rules 271(ii) and 272(4), which the Finance Department deferred pending rule amendment.

Citations 2025:UHC:7490-DB

Practical Impact

Category Impact
Binding On State Government and all subordinate courts in Uttarakhand
Persuasive For Other High Courts considering similar pension disputes

What’s New / What Lawyers Should Note

  • Clarifies that proviso (ii) of Rule 271 and proviso (4) of Rule 272 apply to all retiring Tribunal members, including those reappointed post-superannuation.
  • Rejects the argument that entitlement is limited to appointees who join the Tribunal before their parent-department superannuation.
  • Holds that a Finance Department opinion on the need to amend rules cannot override the statutory text.
  • Directs state authorities to recalculate pension and gratuity within 12 weeks, providing a clear timeline for implementation.

Summary of Legal Reasoning

  1. Examined proviso (ii) of Rule 271 and proviso (4) of Rule 272 of the Uttarakhand Cooperative Societies Rules, 2004.
  2. Rejected the State’s narrow interpretation excluding members reappointed after superannuation.
  3. Held that these rules are pari materia with corresponding UP Cooperative Societies provisions.
  4. Applied plain-text interpretation to conclude entitlement for any retiring Tribunal member.
  5. Directed revision of pension and other retiral benefits within 12 weeks for service rendered as Tribunal members.

Arguments by the Parties

Petitioners

  • Proviso (ii) of Rule 271 and proviso (4) of Rule 272 entitle them to recalculated pension, gratuity and leave-encashment as Tribunal members.
  • Similar, pari materia provisions in the UP Cooperative Societies Rules support their claim.

State

  • Rule 271 applies only to members who had not superannuated before their appointment to the Tribunal.
  • Reappointed members post-superannuation are not covered by the proviso.

Factual Background

The petitioners, a retired IAS officer and a retired Additional Registrar, were appointed as Members of the Uttarakhand Cooperative Tribunal after their initial superannuation in 2008 and 2010. They served until reaching 66 years of age, retiring in 2014 and 2016, respectively. Although they received parent-service pension and gratuity, their Tribunal tenures were not factored into those calculations. After representations to the Competent Authority and a Finance Department review (which acknowledged the entitlement but called for rule amendment), they moved this writ petition seeking a mandamus for pension revision.

Statutory Analysis

  • Proviso (ii) to Rule 271: Entitles a retiring Chairman or Member of the Tribunal to additional pension, gratuity and leave-encashment recalculated as if they had continued in service, minus amounts already paid.
  • Proviso (4) to Rule 272: Grants every person appointed as Chairman or Member of the Tribunal pension and gratuity on par with Group ‘A’ State Government officers.
  • The court applied a textual interpretation, finding no restriction in these provisos limiting applicability to those who joined before superannuation.

Alert Indicators

  • ✔ Precedent Followed

Citations

  • 2025:UHC:7490-DB

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