The State Of Maharashtra vs. Balkrishna Vyankatrao Tambare

Court:Supreme Court of India
Judge:Hon'ble Sudhanshu Dhulia, K. Vinod Chandran
Case Status:Disposed
Order Date:3 Mar 2025
CNR:SCIN010048862025

AI Summary

The Supreme Court has decisively upheld a High Court ruling, disallowing the State of Maharashtra from withdrawing previously granted 'excellent work' certificates and advance increments to its employees. This decision, primarily based on the State's highly belated action and lack of merit, reinforces the principle of administrative fairness and protection of vested employee benefits, signaling a critical stance against arbitrary and delayed governmental reversals.

Ratio Decidendi:
The Supreme Court will not exercise its discretionary jurisdiction under Article 136 of the Constitution to interfere with a High Court's order that protects employee benefits from withdrawal, especially when the State's action to effectuate such withdrawal is found to be 'highly belated' and otherwise lacking merit.
Obiter Dicta:
The Court observed a pattern of similar matters being dismissed on grounds of delay and merits, signaling a general judicial reluctance to entertain belated challenges to settled employee benefits by governmental entities.

Case Identifiers

Primary Case No:Diary No. 4886/2025
Case Type:Special Leave Petition (Civil)
Case Sub-Type:SLP - Service Matter - Employee Benefits Withdrawal
Secondary Case Numbers:Diary No. 4882/2025, Diary No. 4885/2025, Diary No. 4891/2025, Diary No. 4881/2025, Diary No. 4875/2025, Diary No. 293/2025, Diary No. 3596/2025, Diary No. 3610/2025, Diary No. 3613/2025, Diary No. 3741/2025, Diary No. 4874/2025, Diary No. 4877/2025, Diary No. 4878/2025, Diary No. 4880/2025, Diary No. 4887/2025, Diary No. 4888/2025, Diary No. 4893/2025, Diary No. 5469/2025, Diary No. 5471/2025, Diary No. 5479/2025, Diary No. 5482/2025, Diary No. 3738/2025, Diary No. 3595/2025, Diary No. 3742/2025, Diary No. 5470/2025, Diary No. 298/2025, Diary No. 4898/2025
Order Date:2025-03-03
Filing Year:2025
Court:Supreme Court of India
Bench:Division Bench
Judges:Hon'ble Sudhanshu Dhulia, Hon'ble K. Vinod Chandran

Petitioner's Counsel

Aaditya Aniruddha Pande
Advocate on Record - Appeared
Siddharth Dharmadhikari
Advocate - Appeared
Sourav Singh
Advocate - Appeared

Advocates on Record

Aaditya Aniruddha Pande

eCourtsIndia AITM

Brief Facts Summary

The State of Maharashtra appealed a High Court order that had protected its workers from the withdrawal of 'excellent work' certificates and advance increments. The High Court had determined that the State's attempt to retract these benefits was significantly delayed and lacked sufficient justification. The Supreme Court dismissed the State's appeal, concurring with the High Court's reasoning and further noting that similar cases had been dismissed on both procedural and substantive grounds.

Timeline of Events

Prior to 2019-10-09

Workers were granted certificates for excellent work and advance increments.

Before 2019-10-09

The State initiated steps to withdraw these benefits from the workers.

2019-10-09

High Court of Judicature at Bombay at Aurangabad allowed writ petitions (WP No. 12356/2019) by workers, preventing the withdrawal of benefits, citing 'highly belated action' by the State.

2025

The State of Maharashtra filed Special Leave Petition (Diary No. 4886/2025 and connected matters) in the Supreme Court.

2025-03-03

Supreme Court heard and dismissed the Special Leave Petition and associated applications, upholding the High Court's order.

Key Factual Findings

The High Court allowed the writ petitions filed by the respondents/workers.

Source: Recited from Lower Court Judgment

The certificate of excellent work and the benefit of advance increment(s) granted to the writ petitioners/workers cannot be withdrawn.

Source: Current Court Finding

The action on the part of the State to withdraw the benefits was highly belated.

Source: Recited from Lower Court Judgment

The High Court's decision was also based on 'other reasons' against the withdrawal.

Source: Recited from Lower Court Judgment

The Supreme Court sees absolutely no reason to interfere with the impugned High Court order under Article 136.

Source: Current Court Finding

The application for condonation of delay was dismissed.

Source: Current Court Finding

The Special Leave Petition was dismissed.

Source: Current Court Finding

Many similar matters before this Court have been dismissed on the ground of delay as well as on merits.

Source: Current Court Finding

Primary Legal Issues

1.Legality of the State's belated withdrawal of employee benefits (certificates of excellent work and advance increments)
2.Scope of interference by the Supreme Court under Article 136 against High Court orders concerning administrative fairness and employee rights

Secondary Legal Issues

1.Principle of delay and laches in administrative actions
2.Protection of vested rights of employees

Questions of Law

Whether the State can unilaterally withdraw employee benefits after a 'highly belated' period, especially when such withdrawal is found to be unjustified by a High Court.
Whether the Supreme Court should exercise its extraordinary jurisdiction under Article 136 to overturn a High Court decision that protects employee benefits against belated administrative withdrawal.

Petitioner's Arguments

The State of Maharashtra (petitioner) sought to challenge the High Court's order which prevented it from withdrawing previously granted certificates of excellent work and advance increments to workers. The State's implicit argument was that the withdrawal was justified or necessary, though this was challenged due to significant delay, necessitating an application for condonation of delay.

Respondent's Arguments

The respondents/workers argued that the High Court's decision to disallow the withdrawal of their benefits was correct, as the State's action was 'highly belated' and lacked proper grounds. They contended that once granted, such benefits should not be arbitrarily withdrawn, especially after considerable delay.

Court's Reasoning

The Supreme Court found no justifiable reason to intervene with the High Court's order, exercising its jurisdiction under Article 136 of the Constitution. The Court specifically noted that the High Court had correctly held the State's action of withdrawing benefits to be 'highly belated' and based on 'other reasons' (implying lack of merit). The Court also considered the fact that numerous similar matters had been dismissed on grounds of both delay and merits, reinforcing its decision.

Judicial Philosophy Indicators:
  • Emphasis on Administrative Fairness
  • Protection of Vested Rights
  • Adherence to Principles of Delay and Laches
Order Nature:Final
Disposition Status:Disposed
Disposition Outcome:Dismissed

Impugned Orders

High Court of Judicature at Bombay at Aurangabad
Case: WP No. 12356/2019
Date: 2019-10-09

Specific Directions

  1. 1.The application for condonation of delay as well as the Special Leave Petition are, accordingly, dismissed.
  2. 2.Pending interlocutory application(s), if any, is/are disposed of.

Precedential Assessment

Persuasive (Supreme Court dismissal on merits and delay)

While a dismissal of an SLP in limine (without a detailed judgment on complex legal points) typically has limited precedential value, this order is persuasive as it reaffirms the principle of non-interference under Article 136 in cases where administrative actions challenging established employee benefits are 'highly belated' and lack merit. The explicit mention of similar past dismissals strengthens its persuasive impact in service law and administrative law contexts.

Tips for Legal Practice

1.Government bodies and their legal counsel must prioritize prompt action in challenging or withdrawing administrative benefits to avoid judicial dismissals based on delay and laches.
2.Lawyers representing employees should emphasize the doctrine of delay and the principle of vested rights when the State attempts belated withdrawal of benefits.
3.When filing SLPs against High Court orders in service matters, petitioners must demonstrate compelling reasons for interference beyond mere disagreement, particularly when lower courts have identified significant administrative delays.

Legal Tags

Service Law Employee Benefits Withdrawal Supreme CourtAdministrative Delay Laches Government Action Judicial ReviewSpecial Leave Petition Dismissal Article 136 Non-InterferenceVested Rights Protection Against State Retrospective ActionHigh Court Judgment Upholding Employee Benefits Finality

Disclaimer: eCourtsIndia (ECI) is not a lawyer and this analysis is generated by ECI AI, it might make mistakes. This is not a legal advice. Please consult with a qualified legal professional for matters requiring legal expertise.

Order Issued After Hearing

Purpose:

Fixed Date by Court

Before:

Hon'ble Sudhanshu Dhulia, Hon'ble K. Vinod Chandran

Stage:

FRESH (FOR ADMISSION) - CIVIL CASES

Remarks:

Dismissed on ground of delay [and on merits]

Listed On:

3 Mar 2025

In:

Judge

Category:

UNKNOWN

Interlocutory Applications:

53965/2025,53969/2025,53971/2025,53975/2025

Original Order Copy

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Order Text

ITEM NO.67

COURT NO.12

SECTION IX

SUPREME COURT OF INDIA RECORD OF PROCEEDINGS

SPECIAL LEAVE PETITION (CIVIL) Diary No. 4882/2025

[Arising out of impugned final judgment and order dated 09-10-2019 in WP No. 12356/2019 passed by the High Court of Judicature at <pre>Bombay at Aurangabad]</pre>

THE STATE OF MAHARASHTRA & ORS.

DILIP GOVINDA SONAWANE & ORS.

Petitioner(s)

VERSUS

Respondent $(s)$

FOR ADMISSION and I.R. IA No. 47148/2025 - CONDONATION OF DELAY IN FILING IA No. 47151/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 47150/2025 - EXEMPTION FROM FILING O.T. IA No. 47147/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES

WTTH

<pre>Diary No(s). 4885/2025 (IX)</pre> IA No. 47605/2025 - CONDONATION OF DELAY IN FILING IA No. 47607/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED **JUDGMENT** IA No. 47608/2025 - EXEMPTION FROM FILING O.T. IA No. 47610/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES
Diary No(s). 4891/2025 (IX)
IA No. 48197/2025 - CONDONATION OF DELAY IN FILING
IA No. 48199/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED
JUDGMENT
IA No. 48200/2025 - EXEMPTION FROM FILING O.T.
IA No. 48201/2025 - PERMISSION TO FILE ADDITIONAL
DOCUMENTS/FACTS/ANNEXURES

Diarv No(s). 4881/2025 (IX) IA No. 49403/2025 - CONDONATION OF DELAY IN FILING IA No. 49404/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 49405/2025 - EXEMPTION FROM FILING O.T. Signa Method VNO. 49406/2025 - PERMISSION TO FILE ADDITIONAL DECUMENTS/FACTS/ANNEXURES 17:01:05 IST<br>Reason: $\mathbf{S}$ Diary No(s). 4875/2025 (IX)

FOR ADMISSION and I.R. IA No. 49279/2025 - CONDONATION OF DELAY IN FILING IA No. 49280/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 49281/2025 - EXEMPTION FROM FILING O.T. IA No. 49282/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 293/2025 (IX) FOR ADMISSION and I.R. IA No. 53341/2025 - CONDONATION OF DELAY IN FILING IA No. 53347/2025 - CONDONATION OF DELAY IN REFILING / CURING THE DEFECTS IA No. 53343/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 53344/2025 - EXEMPTION FROM FILING O.T. IA No. 53346/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 3596/2025 (IX) IA No. 53065/2025 - CONDONATION OF DELAY IN FILING IA No. 53072/2025 - CONDONATION OF DELAY IN REFILING / CURING THE DEFECTS IA No. 53066/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 53067/2025 - EXEMPTION FROM FILING O.T. IA No. 53068/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 3610/2025 (IX) FOR ADMISSION and I.R. IA No. 54956/2025 - CONDONATION OF DELAY IN FILING IA No. 54962/2025 - CONDONATION OF DELAY IN REFILING / CURING THE DEFECTS IA No. 54957/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 54958/2025 - EXEMPTION FROM FILING O.T. IA No. 54960/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 3613/2025 (IX) IA No. 53672/2025 - CONDONATION OF DELAY IN FILING IA No. 53675/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 53677/2025 - EXEMPTION FROM FILING O.T. IA No. 53678/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 3741/2025 (IX)

IA No. 54357/2025 - CONDONATION OF DELAY IN FILING IA No. 54364/2025 - CONDONATION OF DELAY IN REFILING / CURING THE DEFECTS IA No. 54358/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 54359/2025 - EXEMPTION FROM FILING O.T. IA No. 54361/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES

Diary No(s). 4874/2025 (IX) FOR ADMISSION and I.R. IA No. 54406/2025 - CONDONATION OF DELAY IN FILING IA No. 54408/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 54409/2025 - EXEMPTION FROM FILING O.T. IA No. 54410/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES

Diary No(s). 4877/2025 (IX) IA No. 54278/2025 - CONDONATION OF DELAY IN FILING IA No. 54281/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 54280/2025 - EXEMPTION FROM FILING O.T. IA No. 54277/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES

Diary No(s). 4878/2025 (IX)

FOR ADMISSION and I.R. IA No. 53249/2025 - CONDONATION OF DELAY IN FILING IA No. 53250/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 53251/2025 - EXEMPTION FROM FILING O.T. IA No. 53252/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES

Diary No(s). 4880/2025 (IX) IA No. 53993/2025 - CONDONATION OF DELAY IN FILING IA No. 53994/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 53996/2025 - EXEMPTION FROM FILING O.T. IA No. 53998/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES

Diary No(s). 4886/2025 (IX) IA No. 53965/2025 - CONDONATION OF DELAY IN FILING IA No. 53969/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 53971/2025 - EXEMPTION FROM FILING O.T. IA No. 53975/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES

Diary No(s). 4887/2025 (IX) IA No. 50580/2025 - CONDONATION OF DELAY IN FILING IA No. 50582/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 50583/2025 - EXEMPTION FROM FILING O.T. IA No. 50584/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 4888/2025 (IX) IA No. 53870/2025 - CONDONATION OF DELAY IN FILING IA No. 53871/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 53873/2025 - EXEMPTION FROM FILING O.T. IA No. 53875/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 4893/2025 (IX) FOR ADMISSION and I.R. IA No. 53275/2025 - CONDONATION OF DELAY IN FILING IA No. 53277/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 53278/2025 - EXEMPTION FROM FILING O.T. IA No. 53279/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 5469/2025 (IX) IA No. 51272/2025 - CONDONATION OF DELAY IN FILING IA No. 51273/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 51275/2025 - EXEMPTION FROM FILING O.T. IA No. 51276/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 5471/2025 (IX) FOR ADMISSION and I.R. IA No. 53559/2025 - CONDONATION OF DELAY IN FILING IA No. 53576/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 53561/2025 - EXEMPTION FROM FILING O.T. IA No. 53564/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 5479/2025 (IX) IA No. 51516/2025 - CONDONATION OF DELAY IN FILING IA No. 51518/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 51519/2025 - EXEMPTION FROM FILING O.T. IA No. 51521/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 5482/2025 (IX) FOR ADMISSION and I.R. IA No. 52814/2025 - CONDONATION OF DELAY IN FILING

IA No. 52815/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 52816/2025 - EXEMPTION FROM FILING O.T. IA No. 52818/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 3738/2025 (IX) IA No. 50339/2025 - CONDONATION OF DELAY IN FILING IA No. 50344/2025 - CONDONATION OF DELAY IN REFILING / CURING THE DEFECTS IA No. 50340/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 50341/2025 - EXEMPTION FROM FILING O.T. IA No. 50343/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 3595/2025 (IX) FOR ADMISSION and I.R. IA No. 55744/2025 - CONDONATION OF DELAY IN FILING IA No. 55750/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 55752/2025 - EXEMPTION FROM FILING O.T. IA No. 55754/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 3742/2025 (IX) IA No. 53163/2025 - CONDONATION OF DELAY IN FILING IA No. 53167/2025 - CONDONATION OF DELAY IN REFILING / CURING THE DEFECTS IA No. 53164/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 53165/2025 - EXEMPTION FROM FILING O.T. IA No. 53166/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 5470/2025 (IX) IA No. 56624/2025 - CONDONATION OF DELAY IN FILING IA No. 56625/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 56626/2025 - EXEMPTION FROM FILING O.T. IA No. 56627/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Diary No(s). 298/2025 (IX) IA No. 56634/2025 - CONDONATION OF DELAY IN FILING IA No. 48701/2025 - CONDONATION OF DELAY IN REFILING / CURING THE DEFECTS IA No. 56635/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 56636/2025 - EXEMPTION FROM FILING O.T. IA No. 56637/2025 - PERMISSION TO FILE ADDITIONAL

DOCUMENTS/FACTS/ANNEXURES

Diary No(s). 4898/2025 (IX) FOR ADMISSION and I.R. IA No. 56617/2025 - CONDONATION OF DELAY IN FILING IA No. 56618/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT IA No. 56619/2025 - EXEMPTION FROM FILING O.T. IA No. 56620/2025 - PERMISSION TO FILE ADDITIONAL DOCUMENTS/FACTS/ANNEXURES Date : 03-03-2025 These matters were called on for hearing today. CORAM : HON'BLE MR. JUSTICE SUDHANSHU DHULIA HON'BLE MR. JUSTICE K. VINOD CHANDRAN For Petitioner(s) Mr. Aaditya Aniruddha Pande, AOR Mr. Siddharth Dharmadhikari, Adv. Mr. Sourav Singh, Adv. For Respondent(s)

UPON hearing the counsel, the Court made the following O R D E R

The High Court vide the impugned order has allowed the writ petitions filed by the respondents/workers. It has been held that the certificate of excellent work and the benefit of advance increment(s) granted to the writ petitioners/workers cannot be withdrawn, as it was a highly belated action on the part of the State and for other reasons.

We see absolutely no reason to interfere with the impugned order in exercise of our jurisdiction under Article 136 of the Constitution of India.

The application for condonation of delay as well as the Special Leave Petition are, accordingly, dismissed.

We are also informed that many of such matters before this Court have been dismissed on the ground of delay as well as on merits.

Pending interlocutory application(s), if any, is/are disposed of.

(BABITA PANDEY) (RENU BALA GAMBHIR) AR-CUM-PS ASSISTANT REGISTRAR

6

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