Case Title: State of Madhya Pradesh Through Principal Secretary & Ors. v. Seema Sharma
Service Law doctrine ‘Equal Pay for Equal Work’ cannot be invoked by an employee merely on the basis that he holds a similar designation or undertakes an identical quantum of work. The Supreme Court explicitly held that, "The doctrine of equal pay for equal work could only be invoked when the employees were similarly circumstanced in every way. Mere similarity of designation or similarity or quantum of work was not determinative of equality in the matter of pay scales. The Court had to consider all the relevant factors such as the mode of recruitment, qualifications for the post, the nature of work, the value of work, responsibilities involved and various other factors."
Moreover, the Court observed that fixation of pay scales is a matter of policy that can be interfered with by the courts only in exceptional cases where there is blatant discrimination between two sets of employees (intra-class) appointed by the same authority, in the same manner, where the eligibility criteria is the same and the duties are identical in every aspect.
In furtherance of this, the Court clearly stated that, “This Court cannot interfere with the policy decision taken by the Government merely because it feels that another decision would have been fairer; or wiser as held by this Court in State of Madhya Pradesh vs. Narmada Bachao Andolan and relied upon and re-affirmed in Sudhir Budakoti & Others (supra).”
The case at hand deals with controversy regarding the applicability of the eligibility criteria for appointment of Museum Assistant-cum- Librarian under the 1987 Rules vis-a-vis the eligibility criteria of appointment of Librarian under the 1990 Rules in the State of Madhya Pradesh, and the difference in pay scales thereof.
It also categorically stated that, "It is also well settled that there can be no equality to a wrong and/or illegality. Just because a librarian may have been erroneously granted the UGC pay scale, that would not entitle others to claim the UGC pay scale, if not applicable under the Rules."