THE RESERVE BANK OF INDIA v. M.T. MANI
Discusses principles of approbate/reprobate, policy decisions, and Article 14 in the context of pension schemes.
Court: Supreme Court of India
Citation: 2025 INSC 769
Decision Date: 23-05-2025
List of Laws
Gratuity Act, 1972; RBI Pension Regulations, 1990; Constitution of India, 1949; General Principles of Law
- Gratuity Act, 1972: The judgment mentions that employees of the RBI prior to 1990 were governed by the Contributory Provident Fund (“CPF”) and the payment of the Gratuity Act, 1972 (“Gratuity Act”). The judgment does not provide further details or analysis of the Gratuity Act.
- RBI Pension Regulations, 1990: The judgment extensively discusses the RBI Pension Regulations, 1990. It notes that the RBI introduced these regulations on 29.10.1990 with approval from its Central Board of Directors. Employees were informed via Administration Circular No. 6 that the regulations would come into effect from 01.11.1990, giving existing employees an option to join the Pension Scheme or continue with the RBI's CPF. All new employees joining on or after 01.11.1990 were to be governed by the 1990 Regulations. Employees in service as of 01.01.1986 who retired before 01.11.1990 were also eligible for pension upon refunding the CPF share of the RBI with accrued interest at 6%. Regulation 31 stated that employees retiring between 01.01.1986 and 31.10.1990, although eligible to join the Pension Scheme, would receive pension only from 01.11.1990 onwards, without arrears. The judgment also mentions Administration Circular No. 5, issued on 07.02.1992, amending the Pension Regulations, 1990, effective from 06.02.1992, giving existing employees (excluding those on leave preparatory to retirement) a fresh option to switch to the Pension Regulations, again without retrospective pensionary benefits.
- Constitution of India, 1949: The judgment refers to Article 14 of the Constitution in the context of whether distinguishing between retirees based on a cut-off date violates the principle of equality. The court cites previous rulings, including *State of Tripura (supra)*, to support the view that financial constraints can justify fixing a cut-off date for extending pensionary benefits or pay revisions without violating Article 14. The judgment states, "economic considerations are germane to governmental policy decisions, and distinguishing between retirees based on such a date does not violate Article 14 of the Constitution." The final judgment states, "There being no violation of the Constitutional, Statutory or Common Law principles, interference by the Division Bench vide the impugned judgment while setting aside the judgement of the Single Judge cannot sustain."
- General Principles of Law: The judgment discusses the principle of approbate and reprobate, stating that the Respondent cannot be permitted to accept the beneficial terms of the pension scheme while rejecting the unfavorable ones. The court emphasizes that the Respondent, having unconditionally accepted all terms of the circulars and fulfilled the conditions, cannot now challenge unfavorable conditions. The judgment also touches upon the concept of policy decisions, stating that policy decisions, especially relating to financial aspects, need not be interfered with. The court cites *Mohammad Ali Imam and Others Vs. State of Bihar and Others* and *State of Punjab and Others v. Amar Nath Goyal and Others* to support this view.
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