पवन कुमार बनाम हरियाणा राज्य
| Citation | (1996) 2 SCC 340 |
| Court | Supreme Court of India |
| Date | 5 January 1996 |
| Year | 1996 |
| Bench | A.M. Ahmadi CJI, B.L. Hansaria J. |
| Acts/Articles | Article 14, Article 16 |
| Category | Haryana-Specific, Service & Employment Law |
Key Principle Established
Pay fixation on promotion must give a minimum benefit. An employee promoted to a higher post cannot draw less pay than what was being drawn in the lower post plus one increment.
Government employees of Haryana challenged pay fixation on promotion where they were not given any meaningful benefit in the higher scale, sometimes drawing the same or less than what they were getting before promotion.
The Court held that promotion to a higher post must carry a real financial benefit. Pay fixation rules must ensure that the promoted employee gets at least one increment above what was being drawn in the lower post. Anomalous pay fixation that results in no benefit is arbitrary and violates Article 14.
This Haryana-origin judgment governs pay fixation on promotion across all government services. It ensures that promotion carries meaningful financial benefit and prevents anomalous situations.
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Read AnalysisThis judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).
22+ years of practice before Punjab & Haryana High Court and Supreme Court of India.