T. Chandrasekhar vs. The State Of Telangana

Held

The Court held that the impugned proceedings, which amended the clauses regarding the recognition of qualifications, were valid. The Court reasoned that the Supreme Court, in its clarificatory order, had established that benefits not previously extended could not be restored. The petitioners' qualifications from IASE, Rajasthan, were not recognized by the respondents until they cleared the special examination conducted by UGC/AICTE. Therefore, the recognition of their qualifications could only be prospective, effective from the date they cleared the UGC/AICTE examination, not retrospectively. The Court found that the respondents had not extended any service benefits or advantages to the petitioners prior to them clearing the UGC/AICTE examination. Consequently, the Court dismissed all the writ petitions, finding no reason to interfere with the impugned orders.

Facts

The petitioners, primarily employees of power distribution and transmission corporations in Telangana, challenged proceedings issued by their employers. These proceedings amended clauses related to their qualifications, specifically concerning degrees obtained from IASE, Rajasthan. The petitioners argued that these amendments were illegal, arbitrary, and contrary to a Supreme Court judgment. They sought a declaration that the amendments were unconstitutional and requested the implementation of the Supreme Court's orders. The core of the dispute revolved around whether their qualifications, obtained from IASE, Rajasthan, should be recognized retrospectively or prospectively, especially after they cleared special examinations conducted by UGC/AICTE. The petitioners contended that since they cleared these examinations, their qualifications should be considered valid from the date of obtaining the degree, not from the date of clearing the UGC/AICTE examination. The respondents, the State of Telangana and its power corporations, argued that benefits not extended earlier could not be restored and that the amendments were justified based on Supreme Court and High Court judgments.

Key Issues

1. Whether the amendment to Clause-C of the impugned proceedings, which altered the recognition of qualifications obtained by the petitioners, is illegal, arbitrary, and contrary to the Supreme Court's judgment in Civil Appeal Nos. 17869-17870 of 2017 and Article 14 of the Constitution of India? Petitioner's contention: The petitioners argued that the impugned proceedings were illegal and arbitrary, violating Article 14 of the Constitution. They relied on the Supreme Court judgment in Orissa Lift Irrigation Ltd. Vs. Rabi Shankar Patro and others (2018(1) SCC 468) and sought its implementation. They contended that since they cleared the special examination conducted by UGC/AICTE, their qualifications should be treated as valid retrospectively. Revenue/State's contention: The respondents argued that the Supreme Court, in a clarificatory order, held that benefits not extended earlier cannot be restored. They asserted that no benefits were extended to the petitioners prior to clearing the UGC/AICTE examination, and therefore, the amended proceedings were justified. They also contended that a previous Andhra Pradesh High Court judgment did not consider the retrospective or prospective validity of degrees, only their validity.