Failure to Upload Names Cannot Debar Benefits – Calcutta High Court Orders Approval of Accompanists as SACT-II

Court upholds equal treatment under Articles 14 and 16 of the Constitution, directs State to rectify administrative lapse.

The High Court of Calcutta, in a landmark decision, has directed the State of West Bengal to approve the status of two accompanists (tabalchis) as State Aided College Teachers (SACT-II) after their names were not uploaded on the prescribed portal due to administrative lapses by the college authority. The judgment, delivered by Justice Subhendu Samanta, underscores the principles of equitable treatment and natural justice, addressing the procedural failures that disadvantaged the petitioners.

Debtosh Natta and Subrata Natta, the petitioners, were engaged as accompanists (tabalchis) in the Music Department of their respective colleges. Despite their regular engagement and performance akin to guest teachers, their names were not uploaded by the college authority within the stipulated deadline as per the State’s directive. Consequently, the State Authority rejected their claims for approval under the SACT-II category, prompting the petitioners to seek judicial intervention.

While this case does not directly deal with medical evidence, the Court stressed the importance of objective evidence and administrative diligence in the decision-making process.
The Court noted the college authority’s admission of its failure to upload the petitioners’ names within the prescribed timeframe. It emphasized that the procedural lapse should not prejudice the rights of the petitioners, who were otherwise eligible for the benefits under the Memo dated 23.12.2019.

The judgment elaborated on the principles of equal treatment and natural justice under Articles 14 and 16 of the Constitution. Justice Samanta highlighted that the denial of the petitioners’ claims, despite similar approvals for accompanists in other colleges, constituted arbitrary and unequal treatment.

“The procedural lapse by the college authority should not result in the deprivation of the petitioners’ rightful claims,” the Court observed. It further noted that the petitioners were performing similar roles as guest teachers, and the administrative error should not negate their eligibility for SACT-II status.

Justice Samanta stated, “Merely not sending the names within a specific time cannot debar the present petitioners from getting their benefits which they were otherwise entitled to. The principle of equitable treatment mandates that similarly situated individuals must receive similar benefits.”

The High Court’s directive to approve the petitioners as State Aided College Teachers (SACT-II) underscores a significant precedent in service law and administrative justice. By setting aside the State’s rejection and mandating a fresh decision within eight weeks, the Court reinforced the importance of equitable treatment and procedural fairness. This judgment is expected to influence future cases involving administrative lapses and the rights of individuals in similar situations.

Date of Decision: 24th June 2024