This article is authored by Subhashree S. It discusses in detail the case of Joginder Singh vs. State of Punjab, which is regarding the constitutional validity of the Punjab Educational Service (Provincialised Cadre) Class III Rules, 1961. It discusses the facts, issues, and arguments of the parties, the significance of the case in the present context, and the judgement. It also presents an issue-wise analysis of the judgement.

Introduction

The Supreme Court of India in Joginder Singh vs. State of Punjab (1962) rendered a significant judgement addressing the constitutional validity of the Punjab Educational Service (Provincialised Cadre) Class III Rules, 1961, on November 16, 1962. This case emerged from an appeal against the Punjab High Court’s decision, where the Court partially upheld Joginder Singh’s petition, which challenged these rules citing violations of Article 14 and Article 16(1) of the Constitution. The examination of this case encompassed intricate aspects of service integration, equality in government employment, and administrative discretion. The core questions in this case resonate far beyond the parties involved. It includes how administrative rights and fundamental rights are balanced. Moreover, the court’s decision not only affects the fate of public servants in Punjab but across India by reaffirming non-discrimination and equal opportunity in government employment as enshrined in the Constitution.

Details of the case

• Name of the case: Joginder Singh vs. State of Punjab (1962)
• Case No.: Civil Appeal No. 388 of 1962
• Equivalent citations: 1963 AIR 913, 1963 SCR SUPL. (2) 169, AIR 1963 SUPREME COURT 913
• Court: Supreme Court of India
• Bench: B.P. Sinha, J.C. Shah, K. Subba Rao, K.N. Wanchoo, and N. Rajagopala Ayyangar, J.
• Appellant: Joginder Singh
• Respondent: State of Punjab
• Judgement Date: 16 November 1962

Facts of Joginder Singh vs. State of Punjab (1962) 

On November 1, 1956, the State of Punjab was reorganised. Patiala and East Punjab State Union (Part ‘B’ State) merged with Punjab. For educational and administrative purposes, this region was maintained as a separate division with a separate cadre of teachers.

The respondent was a “junior vernacular teacher” in a District Board High School in Hoshiarpur. On September 27, 1957, the Government of Punjab issued executive instructions as communicated from the secretary to the education department to the director of public institutions for changing the status and service conditions of such teachers and by which these (District Board and Municipal cadre) teachers would become state employees. It took effect on October 1, 1957, and was ratified by legislation in 1959 having retroactive effect. Before October 1, 1957, in Punjab (excluding Patiala and East Punjab State Union), there were two types of schools: schools maintained by district and municipal boards and others maintained by states. 

The position and condition of the services of teachers employed in state schools were governed by “The Punjab Educational Service Class III School Cadre Rules, 1955,” framed under Article 309 of the Constitution and promulgated on May 30, 1957. These rules governed qualifications, recruitment authority, service conditions, and seniority. The appendices of the rules contained salary scales for teachers falling into different grades, which were revised by the government by issuing an order on July 23, 1957, under the recommendation of the pay review committee. Paragraph 3 of the scheme applied to employees in the education department, and teachers were categorised based on their qualifications into categories ‘A’ and ‘B’. Accordingly, junior teachers (Category B) were divided into three groups: 

1. Head Master: There was no fixed number; it depended upon the number of schools in which they could function.
2. Middle Scale: 15% of junior teachers, including head masters, although they were on a still higher scale of salary, had a salary scale of 120-5-175 (where 120 was the base salary, 5 was an annual increment, and 175 was the maximum salary achievable in this scale). 
3. Lower Scale: The remaining 85% of junior teachers on a salary scale of 60-4-80 (where 60 was the base salary, 4 was an annual increment, and 80 was the maximum salary achievable on this scale).

And that 15% of junior teachers were to be promoted to middle scale based on seniority and merit, and the rest remained on lower sales.

As the provincialisation (which is the process by which schools previously managed by local bodies such as municipal and district boards were taken over by the state government) was executed as a result of government instruction dated October 1, 1957, the schools previously run by municipal and district boards in Ambala and Jullundur Divisions were taken over by the Government of Punjab, Department of Education. 

There were 20,709 junior teachers in the schools that were taken over. The government applied the same 15:85 ratio (middle to lower scale) used for State cadre junior teachers in the July 23, 1957, government order. As a result, 3,184 teachers were placed on the middle scale, and the rest, 17,525, were in the lower grade with a minimum salary. It was done to ensure that junior teachers in the provincialised local body schools also received the same grades of pay and allowances as their counterparts in government employment. 

Subsequent to this action, the government had three questions for consideration:

1. Whether provincialised and state cadre teachers should be kept separate or integrated?
2. If integrated, how would seniority be determined?
3. If not integrated, what should be the relationship between the two cadres?

The government’s decision on these considerations was communicated in a letter as a policy statement dated January 27, 1960. Its decision was as follows:

1. The two cadres that are provincialised and the state teacher cadres would remain distinct.
2. The government will formulate principles for promotions within each cadre, from the lower to the middle grade. 

This decision by the government of Punjab led to this case, where the respondent challenged the decision’s validity by filing a petition under Article 226, stating that it lacked statutory force and that it was not framed under Article 309 of the constitution. To address the objection, the Punjab government promulgated the impugned rules. Eventually, these rules conformed to the formal requirement under Article 309 of the Constitution, but otherwise they were identical to the 1960 directions. Thus, the respondent’s petition was then converted to challenge the constitutional validity of the impugned rules instead of the government’s 1960 directions. 

Arguments made in the High Court in support of the challenge to the validity of these rules were:

1. It was argued that when the order was executed in October 1957, it granted provincialised teachers the same grades, pay scales, and allowances with equal rights and conditions as state cadre teachers. This implies the complete integration of provincialised and state cadre teachers into a single class. Thus, any latter order that made both distinct was discriminatory under Article 14 of the Constitution. 
2. The rules discriminated against provincialised teachers against promotion to the middle scale, violating Article 16(1).
3. Due to irrational classification, there was a disparity in pensions, thus violating Article 14 of the Constitution. 

Arguments made in the High Court against the challenge to the validity of these rules were:

1. There is a significant difference in qualification and recruitment methods, where state cadres required higher qualifications and were recruited by the public service commission, unlike the provincialised service.

The Hon’ble High Court of Punjab agreed with the contentions of the respondent in creating 2 cadres and held that they were considered to be government servants of the same class and that the impugned rules deprived provincialised cadre teachers of equality of opportunity for promotion. Moreover, it was held that treating recruitment to provincialised cadre vacancies as in the state cadre and maintaining a uniform ratio of 15% and 85% between higher and lower scale salary teachers was discriminatory. Thus, Rule 2 (definitions of 2 cadres) and Rule 3 (effect on promotion) of the Punjab Educational Service (Provincialised Cadre) Class III Rules, 1961, were declared void.

With regards to the pension, the Court rejected the contentions, finding no violation of Article 14 of the Constitution. 

It is from this judgement that an appeal was made by the state with special leave. 

When the Supreme Court commenced its hearing on this appeal, a preliminary objection was raised by the respondent. It was contended that along with Joginder Singh, 3 other similar petitions were filed before the Hon’ble Punjab High Court, namely:

• Two junior teachers (Writ Petitions 161 and 162 of 1961).
• A Head Master, Amrik Singh (Writ Petition 163 of 1961).

All four petitions were disposed of by the common judgement, which granted the same relief to all the petitioners. The State only appealed the decision in the petition of Joginder Singh and not in 3 other petitions. Therefore, the counsel of the respondent, Mr. Agarwal, argued that granting different relief in this appeal would create inconsistent decrees as the orders of the other  3 petitions have become final. 

However, the Court found no merit in this objection and decided that there was no bar to hearing an appeal. The Court further held that the finality of the orders of the 3 petitions by the Punjab High Court will be retained in case the state government’s appeal in this case succeeds. And thus the respondent and the general law applicable to everyone else, except the 3 petitioners, would be as laid down by the Court in this case. 

Issues raised 

1. Whether the order dated September 27, 1957, effectively integrated the provincialised teachers with the existing state educational service members?
2. Whether the impugned rules violated Articles 14 and 16(1) of the Constitution?
3. Whether the government decision to phase out the provincialised cadre is unconstitutional?

Arguments of the parties

Appellant 

• The appellant argued that the government carefully considered the precise status of the provincialised teachers and their relationship with the state cadre teachers, thus leading to the promulgation of the impugned rules. 
• Furthermore, it was contended that the government had 3 considerations for determining the seniority of the provincialised teachers in relation to existing government staff and had 3 alternatives for integrating two services:

1. Grouping formally, counting the full service of local body teachers for a joint seniority list.
2. Integrating both services and counting service time from the date of provincialisation.
3. Keeping separate groups for provincialised staff and existing government school staff.

The government opted for the third option to ensure a good education policy and protect the interests of teachers. 

• It was argued that they were competent to make decisions regarding the service conditions of provincialised staff even after the process of provincialisation. This meant that all service rules, including rules of seniority, did not automatically apply to provincialised staff on October 1, 1957.
• There was a reasonable classification between the state cadre and the provincialised cadre, as they form separate cadres for the purpose of promotion and thus no discrimination.
• Counsel relied on precedents set by the Supreme Court in previous cases like All India Station Masters’ & Assistant Station Masters’ Association vs. General Manager (1959) C.R. and Kishori Mohanlal Bakshi vs. The Union of India (1961), which established that equality of opportunity as in Article 16(1) applies only within the same class of employees, not between different classes, and contended that provincialised cadre was newly created when district and municipal board schools were taken over by the government and that it forms separate grades with different employment conditions. Therefore, Article 16 does not prohibit the creation of different grades in government services, and therefore there was no denial of equality of opportunity between citizens holding posts in different grades.

Respondent  

• There might be differences in qualifications to be recruited as teachers in the municipal or district boards and state cadre, but it becomes irrelevant as to when the provincialisation occurred as the schools in which they were formerly employed were taken over by the State. Moreover, under the order of September 27, 1957, both the cadre teachers did the same work and had the same pay scales, and there exists complete interchangeability where the provincialised teachers can be transferred to state schools and vice versa, thus showing the effect of complete integration. Furthermore, to reinforce the statement, a paragraph of the memorandum of September 27, 1957, was relied on, which stated that provincialised teachers receive the same pay scale and allowances as their counterparts already employed by the government (state cadre teachers). 
• It was contended that the impugned rules brought the division of the united services by creating two new cadres with differences between members of services with no intelligible differential as there are similar grades and scales of pay and almost similar other conditions of service between two services, thus it is in violation of Article 14. It was further contended that Article 14 has been violated by creating or maintaining two parallel services of employees doing the same work but with differences either in their emoluments or their conditions of service.
• It was contended that Article 16(1) was violated because both cadre teachers were subjected to the same ratio (15:85) for promotions to higher scales, due to which even the experienced provincialised teachers could be placed in lower positions compared to the new state cadre teachers because of the less number of teacher in the state cadre. As of October 1, 1957, there were only 107 teachers in the state cadre, of whom 15% would have been in the selection cadre, whereas in the provincialised cadre there were 20709 teachers, of whom 15% would have been in the selection cadre, and as the years progressed, recruitment in the provincialised cadre was barred and only conducted in the state cadre, which escalated the promotion opportunity in the state cadre against the provincialised cadre. 

Laws and provisions discussed 

Punjab Educational Service (Provincialised Cadre) Class III Rules, 1961: 

Rule 2: Definitions

Clause(d) defines “service” as “The Punjab Educational (Provincialised Cadre) Class III Service”.

Clause (e) defines “state Cadre” as “The Punjab Educational (State Service) Class III (School Cadre)”. 

The High Court struck down these definitions in their judgement.

Rule 3: Number and character of posts

The service included posts listed in Appendix ‘A’ but was a diminishing one.

New posts

Posts created for any provincialised school after it was taken over by the government became part of the state cadre or a similar educational state service, not the provincialised service. 

Existing vacancies

Headmasters and selection grade teachers 

Vacant posts on October 1, 1957, remained in the provincialised service and were not transferred, which means they stayed part of the group of teachers taken over from local authorities.

When teachers in ordinary pay scale positions were promoted to become headmasters or selection grade teachers, the vacancy created in ordinary pay scale was transferred to state cadre.

Ordinary pay-scale posts

Vacant posts of district or municipal board teachers as of October 1, 1957, on the ordinary pay scale were transferred to the state cadre.

Handling vacancies after provincialisation

• The vacancies after provincialisation due to promotion and retirements were managed by splitting the vacant posts into blocks of 7 and 6. 
• For each block of 7 vacancies, the first six vacancies included selection grade posts, and for blocks of 6 vacancies, the first five vacancies included selection-grade posts. These selection grade posts remained within the provincialised service. The last vacancy in each block was transferred to the state cadre. If the last vacancy wasn’t a selection grade position, another selection grade position in that block was moved instead. If this couldn’t be done in the same block, it was done in the next block, but not later.
• Ordinary pay scale posts: An equal number of ordinary pay scale positions in each block were transferred to the state cadre. 

Rule 4: Liability of transfer

Members of the service part of the state-wise cadre could be posted to any government or provincialised school in the state, while members of the service part of the district-wise cadre could be posted within the district.

Rule 5: Confirmation

Members of the service who were confirmed before provisionalization were deemed to be confirmed in the service.

Rule 8: Method of recruitment

• Selection Grade vacancies that remained after transferring some to the state cadre were filled through promotions from within the existing lower grade of the same cadre. 
• Qualifications for promotion did not require junior teachers to be matriculates; instead, “junior trained,” “junior basic trained,” or “special certificate teachers” with five years of teaching experience were sufficient.
• Promotion is not solely based on seniority; rather, it is also based on merit. 

Rule 9: Method of determination of seniority 

This rule laid down the method of how seniority of the members of the services was determined. It was determined by the dates of their continuous appointments in the service.

Issue-wise analysis of judgement

Whether the order dated September 27, 1957, effectively integrated the provincialised teachers with the existing state educational service members

To solve this question, the Supreme Court examined the terms of the order dated September 27, 1957, carefully to find out whether the order intended to be or achieved complete integration.

Firstly, the Court rejected the argument of the respondent that the memorandum dated September 27, 1957, has integrated provincialised and state cadre teachers. This is because the Court found a difference in rules regarding pensions for state cadre employees and provincialised cadres, where the state cadre pension was governed by para 11 of the Class III School Cadre Rules, 1955, and the same was not applicable to provincialised teachers. This complaint was also raised before the High Court by the respondent, but the High Court rejected the same, and no appeal against it was made by the respondent. Thus, it is agreed that the para 11 of the Class III School Cadre Rules, 1955, does not apply to the conditions and amount of pensions given to the provincialised teachers. 

Secondly, Rule 9 of the Class III School Cadre Rules, 1955, shows the distinction in both cadres. Under Rule 9, the seniority among the members of the state cadre holding the same class of posts and in the same or identical grades of pay is determined by the date of their confirmation in such posts. Thus, there was no interpretation as to whether Rule 9 is applicable for determining the seniority between provincialised teachers and state cadre employees. Moreover, under Rule 9, the date of confirmation of service is pertinent to determining the seniority; therefore, the order dated September 27, 1957, cannot be interpreted to mean that all the provincialised teachers were confirmed in the state cadre on October 1, 1957, as it was possible that many were still on probation in board schools on October 1, 1957, and had not been confirmed, and thus they cannot be considered as automatically confirmed in the state cadre for the purpose of determining the seniority of state service members. 

Furthermore, there was no specific provision in the order that explicitly shows the intention to integrate; rather, the provision specifying that the provincialised teachers should receive the same pay and allowances suggests that there was no intention to integrate, as if integration were intended, the provincialised teachers would naturally receive the same pay and allowances due to integration, making separate provisions unnecessary. 

Thirdly, for state cadre teachers, a minimum education qualification of being matriculated with five years of teaching experience was required for the purpose of promotion to selection grade, whereas out of 20,000 provincialised teachers, around 12,000-13,000 had not passed the matriculation examination. Thus, applying state cadre rules to these unqualified teachers would have caused significant hardship; therefore, this hardship and differences in qualification requirements suggest that complete integration was not intended or achieved. 

Thus, the order dated September 27, 1957, beyond proving equality in pay and grades, does not intend or provide for any further integration of provincialised teachers with the state service.

Further, the Court considered that there was a strong force in the submissions of the appellant that when provincialisation was done, there was a question about the status and seniority of provincialised teachers compared to state cadre teachers. Hence, after careful consideration, the government incorporated Rule 3, which was to maintain the separate cadres for the provincialised staff and the staff of the government schools, which creates balance in the interests of both groups while keeping them apart. This consideration was done from 1957 to January 1960, and the respondent did not deny this consideration even though they questioned the rule’s validity. 

Therefore, there was no integration of both services, and integration would have been meaningless unless it was complete; partial integration did not exist. Furthermore, it was not the impugned rules that created the distinction; rather, the distinction existed independently of the impugned rules.

Whether the impugned rules violated Articles 14 and 16(1) of the Constitution

To answer this issue, the Court observed that the respondent’s argument in the High Court regarding whether having two services with similar pay and conditions was discriminatory under Article 14 was countered by the appellant. The appellant highlighted significant differences in qualifications and recruitment methods between the two groups, noting that state cadre positions required higher qualifications and were recruited by the public service commission, unlike provincialised teachers. This contention was not rebutted by the respondent. Thus, the Court concluded that significant differences existed, providing no basis for claiming discrimination under Article 14 for treating the groups differently.

Further, this argument was based on two ideas:

1. Equal work should receive equal pay, and
2. If there’s equality in pay and work, there should be equal conditions of service.

The Court noted that the first idea was rejected by this Court in the case of Kishori Mohan Lal vs. Union of India, 1961, where it was clarified that having different pay scales for officers doing similar work doesn’t violate Article 14, as incremental pay scales based on service duration are allowed, and the abstract idea doesn’t apply to Article 14. Further, the court stated that, in its opinion, the second idea was unsound. For instance, the government creating a new service for the same work with different promotion prospects isn’t unconstitutional. This was because the government needs the liberty to organise its workforce effectively. There may be instances where temporary or emergency staff are needed, who may perform the same duties and receive the same pay as permanent staff but under different employment conditions. Denying this would impose unnecessary restrictions on the administration. 

While concluding, the Court held that both services started independently, with significant differences, and the government order on September 27, 1957, did not integrate them into a single service. Since they were not integrated, there was no issue of inter se seniority or comparisons for promotions between the two services. The dissimilarity in treatment between the two services does not constitute a denial of equal opportunity, and within each group, there was no denial of freedom guaranteed under Articles 14 and 16(1) of the Constitution. Therefore, the High Court’s judgement that the rules created two classes from a single class and introduced discrimination has no factual basis. 

It is pertinent to note the dissenting judgement given by J.C. Shah, where the Court highlighted the argument of the respondent on the discrimination experienced by provincialised teachers in promotions against state cadre, that due to the uniform ratio for promotion to higher scales, some provincialised teachers were continuously relegated to a junior position, even to new entrants in state cadre. The court noted that compliance with the rules would lead to a situation where new entrants in the state service could be promoted to the higher scale while many experienced provincialised teachers remained in the lower scale, despite being senior and qualified for promotions. Further, the court emphasised that the solicitor general representing the state did not dispute that this would be the consequence of adhering to the scheme, even though provincialised teachers could be placed in lower positions compared to new state cadre teachers. 

The Court also emphasised the arguments made by the appellate that Article 16 does not apply between different classes; rather, it applies only within the same class of employees. It held that there was no valid basis for classification between state cadre and provincialised cadre members regarding promotions when both cadres received the same pay, performed similar duties, and occupied the same posts. It was held that in the All India Station Master’s case, the railway employees were considered a distinct class due to distinct duties and separate rules for recruitment, pay, and promotion. The court concluded that there wasn’t sufficient justification for treating members of two cadres differently regarding promotion without violating Article 16(1). Further, highlighting Kishori Mohanlal Bakshi’s case (Supra), where income tax services underwent reconstitution, resulting in two classes of officers who both performed similar work but had different pay scales. The court found that, however, in the present case, both cadres were not in the different grades. While there might be variations in the degree of efficiency during recruitment to the service, they form part of an amalgamated educational service. Further, both cadres have the same conditions for promotions in that teachers need to be matriculated and have five years of service in the education department. Finally, the Court noted that the government initially admitted the provincialised teachers into a single unit of employment and then, through retrospective rules, introduced differential treatment between two sections, thus violating Article 16. Therefore, in the matter of promotion, there was a violation, and the appeal must therefore fail. 

Whether the government decision to phase out the provincialised cadre is unconstitutional

This issue arises because Rule 3 of the impugned rules states that vacancies in the provincialised cadre would not be filled by entrants to that cadre but would be treated as entrants to the state cadre. This results in the gradual diminishing of provincialised cadres over approximately 30 years while that state cadre expands. The Court noted that this issue was the source of prejudice.

It held that this issue can be answered by addressing the issue of whether the teachers have a fundamental right to maintain their cadre strength at its original level. The Court answered this question negatively, stating that they do not have such a right. If the cadre strength decreases naturally as a result of fewer selection posts, the predetermined proportion (15%) of selection posts must also decrease. Thus, the claim of the respondent that the government decision to phase out the provincialised cadre is unconstitutional is clearly unreasonable and cannot be supported, as the respondent would need to prove that the government was bound by law to fill every vacancy in the provincialised cadre to keep the number of teachers the same as it was in 1957. Therefore, the government’s decision to reduce the cadre’s strength was not unconstitutional.

Judgement in Joginder Singh vs. State of Punjab (1962)

The Hon’ble Supreme Court, in view of the opinion of the majority, allowed the appeal and set aside the High Court’s order striking down Rules 2(d) and (e) and Rule 3 of the Punjab Educational Service (Provincialised Cadre) Class III Rules, 1961, regarding promotion.

Rationale behind this judgement

The reason behind the majority opinion was that the two services started independently, continued independently, and were never integrated into one service. Thus, the dissimilarity in their treatment did not amount to a denial of equal opportunity.

The reason behind the dissenting opinion is that they believed that the rules provided differential treatment between the two cadres in terms of promotion, which was unconstitutional.

Significance of the case in the present context

This case has significance in the arena of administrative law and public employment. The Court’s judgement established clear boundaries regarding the authority of the state to classify and manage its workforce. The Court emphasised that when there are significant differences, then reasonable classification, which is a fundamental principle in administrative law which allows the state to classify its workforce based on relevant criteria, ensuring that the right to equality enshrined in the Constitution is not violated, is permissible. This principle safeguards administrative discretion, which is the flexibility guaranteed to officials to enforce the law by ensuring that it is enforced within the boundaries of the law.

In contemporary times, this ruling emphasises that equal pay for equal work is not an absolute principle under Article 14 when different grades and service conditions are justifiable. Moreover, it provides a clear understanding of how state policies regarding public sector employment can be designed to balance efficiency and equity. 

Moreover, it highlighted the judiciary’s role in scrutinising government policies and ensuring no arbitrary and upholding constitutional rights. The dissenting opinion is particularly notable as it brings to light the potential inequalities arising from differential treatment in promotions, and this aspect emphasises the need for vigilant judicial oversight to protect against systemic biases in contemporary times. 

Conclusion

The Supreme Court’s judgement examined service integration, classification, and equal opportunity in public employment. The majority upheld the state’s discretion to maintain separate cadres for provincialised and state cadre teachers, justifying differential treatment based on distinct recruitment and qualification criteria. However, dissenting opinions highlight the unfairness of promotion policies that disregard the service and experiences of the provincialised cadre teachers. 

Thus, the case balances administrative discretion with equality, offering insights for fair public sector employment policies. Moreover, the aspect of Article 14 that can be claimed to be violated only when differential treatment within the class is done and not otherwise is established precisely. The principle that equal work should receive equal pay and that equal conditions of service are not a necessary element of Article 14 was also clearly established in this case. Henceforth, the judiciary ensured the prevalence of justice, equality, and liberty for individuals. 

Frequently Asked Questions (FAQs)

What was the central issue in the Joginder Singh vs. State of Punjab case?

The central issue was whether the state’s decision to maintain separate cadres for provincialised and state cadre teachers, with distinct recruitment and qualification criteria, is in violation of Articles 14 and 16(1).

How did the Supreme Court justify differential treatment between the two cadres of teachers?

The Court justified differential treatment with distinct recruitment and qualification criteria for each cadre and upheld the state’s discretion to maintain separate cadres. 

What was the dissenting opinion’s main concern regarding the judgement?

It was regarding the unfairness of promotion policies that did not adequately consider the service and experience of employees from different cadres. It emphasises the judiciary’s role in preventing discriminatory practices within public administration.

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