Parity Cannot Be Denied by Geography: Supreme Court Holds Jharkhand Bound by Patna HC's Judgment, Orders Pay Revision for Industries Officer

“Once Judicial Declaration Is Made, Others Similarly Situated Need Not Knock The Court’s Doors Individually” – On 16 December 2025, the Supreme Court of India delivered a powerful affirmation of constitutional equality and judicial discipline in Sanjay Kumar Upadhyay v. State of Jharkhand & Ors. (Civil Appeal No. 14046 of 2024), reinstating a 2011 Jharkhand High Court order that had granted revised pay scales to the appellant—a Industries Extension Officer—based on parity with similarly placed employees. The Court held that the 1993 judgment of the Patna High Court in Nagendra Sahani v. State of Bihar is binding on the State of Jharkhand under Section 34(4) of the Bihar Reorganisation Act, 2000.

“The statutory provisions... mandate that judicial orders of the Patna High Court continue to bind the successor State. The judgment in Nagendra Sahani, which granted identical relief to similarly situated employees... has binding effect,” declared a bench comprising Justice J.K. Maheshwari and Justice Vijay Bishnoi.

This ruling ends a 20-year-long battle for pay equity by Sanjay Kumar Upadhyay, who had been allocated to Jharkhand after the bifurcation of Bihar, and was denied parity despite being part of the same recruitment process as those granted higher pay scales.

“Patna High Court’s Judgment Deemed Binding in Jharkhand After Reorganisation” – SC Reads Down Misinterpretation by Jharkhand HC Division Bench

In a scathing reversal of the Jharkhand High Court Division Bench’s 2022 decision, the Supreme Court held that it erred in treating the Patna High Court’s decision as merely persuasive.

“Once the provision of law deems that all the orders and judgments of the High Court of Patna shall have the same effect as an order passed by the Jharkhand High Court, the Division Bench had limited options — either to follow the precedent or refer it to a larger bench,” the Supreme Court stated, invoking the principle laid down in Mary Pushpam v. Telvi Curusumary.

Under Section 34(4) of the Bihar Reorganisation Act, the Court noted, all judgments delivered by the Patna High Court prior to bifurcation “shall for all purposes have effect, not only as an order of the High Court at Patna, but also as an order made by the High Court of Jharkhand.”

The Court criticized the High Court for ignoring this statutory continuity and for brushing aside binding precedent under the guise of policy autonomy.

“A Continuing Cause of Action Cannot Be Dismissed as Delay” – Apex Court Strikes Down Argument of Laches in Service Matters

Rejecting the respondent-employer’s claim that the appellant’s writ petition filed in 2005 suffered from an “inordinate delay” of over two decades, the Supreme Court ruled that claims of pay parity arising from continuing anomalies in pay scales constitute a recurring cause of action.

“The claim to be paid the correct salary... is a right which subsists during the entire tenure of service... Every month when the employee receives lesser pay than his similarly situated counterparts constitutes a fresh cause of action,” the Court observed, quoting its earlier ruling in M.R. Gupta v. Union of India.

The Court pointed out that the appellant had made representations in 2001 and 2002, which were rejected in 2004. He filed the writ petition in 2005—“within a reasonable time after rejection”—demonstrating that he was not “sleeping over his rights.”

“State Cannot Plead Financial Impact to Justify Constitutional Injustice” – Supreme Court Reprimands Arbitrary Denial of Equal Pay

In restoring the Single Judge’s well-reasoned 2011 decision, which had granted the appellant the higher pay scale of ₹1600–2780 from the date of his appointment in 1992, the Supreme Court made it clear that financial implications and administrative convenience cannot override Article 14 of the Constitution.

“The principle of equality... brooks no discrimination between persons who are similarly situated, and any differential treatment must be based on intelligible differentia having a rational nexus,” the Court reminded the State.

The Division Bench had set aside the Single Judge’s order, citing “cascading effects” and “policy decisions,” but failed to justify how the appellant’s case was factually or legally distinguishable from those who had been granted relief in Nagendra Sahani.

“Once a Declaration of Law Is Made, Others Need Not Litigate Again” – Supreme Court Enforces Equitable Doctrine

The judgment strongly reiterated the doctrine that where a court has made a declaration in favor of a group of similarly situated persons, others need not file identical cases to claim the same benefit.

“Where a citizen has approached the court and obtained a declaration of law in his favour, others similarly situated ought to be extended the benefit without the need for them to go to court,” said the bench, citing Suprita Chandel v. Union of India and the landmark Amrit Lal Berry ruling.

The Court found it “grossly unjust” that despite being part of the same recruitment and performing the same duties, the appellant was arbitrarily denied equal pay because of inter-departmental allocations post-recruitment.

Supreme Court Orders Compliance Within Three Months

In its final orders, the Supreme Court directed the State of Jharkhand to implement the revised pay scale for Sanjay Kumar Upadhyay with effect from the date of his appointment and to pay arrears accordingly.

“We allow this appeal... The directions as contained in the judgment of the learned Single Judge be now complied within three months,” the Court ordered.

The Court also awarded litigation costs to the appellant, reaffirming its strong disapproval of the State’s attempt to deny equal treatment based on jurisdictional technicalities and administrative convenience.

Date of Decision: 16 December 2025