Panchayat Teachers' Pay Dreams Dashed: Chhattisgarh HC Upholds Service Divide

In a decisive ruling, the High Court of Chhattisgarh at Bilaspur dismissed an intra-court appeal by eight educators, led by Mangal Ram Usendi, rejecting their claim for time-bound pay scale benefits. A Division Bench comprising Chief Justice Ramesh Sinha and Justice Ravindra Kumar Agrawal affirmed a Single Judge's order, emphasizing the clear separation between Panchayat-employed Shiksha Karmis and regular School Education Department teachers.

Roots in Rural Classrooms: The Long Road to Absorption

The appellants—headmasters and teachers from government schools in Uttar Bastar Kanker—were appointed as Shiksha Karmi Grade-III/II between 1998 and 2008 by Janpad and Zila Panchayats. Their roles involved primary and middle school education in remote Antagarh block areas. Services were regularized locally but remained under Panchayat governance per the Chhattisgarh Panchayat Shiksha Karmi (Recruitment and Conditions of Service) Rules, 2007 .

A pivotal shift occurred via a State policy on 30.06.2018, absorbing these educators into the School Education Department. However, clauses 4 and 5 explicitly barred arrears or pre-01.07.2018 benefits, tying service counting from absorption onward. The core dispute: entitlement to Kramonnati Vetanman (time-bound increments after 10/20 years) under a 10.03.2017 circular meant for School Education staff.

They approached via writ petition (WPS No. 8779/2025), dismissed on 24.11.2025, leading to this appeal (WA No. 310/2026).

Parity Plea vs Policy Wall: Clash of Claims

Appellants' Push for Equality : Represented by advocate Ashok Patil, they argued identical circumstances to Smt. Sona Sahu (WA No. 261/2023), where benefits were granted post-Supreme Court dismissal of SLP in 2025. Having served over a decade pre-circular, they sought first/second Kramonnati Vetanman , claiming post-absorption continuity and parity with government teachers. The 2017 circular, they urged, should retroactively apply.

State's Firm Stand : Government Advocate Prasun Bhaduri countered that pre-2018, appellants were Panchayat cadre employees, not State Government servants. The circular targeted Assistant Teachers under School Education, per 1999 precedents. Absorption policy precluded pre-2018 arrears, and Panchayat rules distinctly governed their conditions. Sona Sahu's case was "peculiar," involving direct government appointment and overlooked circulars.

Drawing the Line: Why Panchayat Service Doesn't Count

The Bench meticulously dissected the 2017 circular's scope, limiting it to "regular Government employees" like School Education Assistant Teachers. Panchayat Shiksha Karmis, governed by Chhattisgarh Panchayat Raj Adhiniyam, 1993 , stood apart until absorption.

Precedents fortified this: In WP(S) Nos. 208/2012, 2530/2017, 10335/2019, 1021/2021, 3369/2021 , similar claims failed, affirming no crossover benefits. Broader principles from State of Punjab v. Jagjit Singh (2017) 1 SCC 148 (equal pay for equal work requires identical situations) and Rohan Vijay Nahar v. State of Maharashtra (2025 INSC 1296) underscored material distinctions.

Sona Sahu was distinguished: Appointed directly as a government teacher in 2005, her benefits navigated cancelled circulars uniquely. Appellants' Panchayat origins barred parity. A prior identical appeal (WA No. 193/2026) was dismissed on 13.03.2026, mirroring facts here.

Key Observations Straight from the Bench

  • "From a bare perusal of the Circular dated 10.03.2017 , it is abundantly clear that the said circular does not deal with or extend benefits to the Teachers belonging to the Panchayat Cadre, including Shiksha Karmi."

  • "Their service conditions were governed by the Chhattisgarh Panchayat Shiksha Karmi (Recruitment and Conditions of Service) Rules, 2007 ... which regulate the service conditions of Panchayat employees."

  • "Clauses 4 and 5 of the absorption order dated 30.06.2018 clearly restrict the grant of any benefit... for the benefit of arrears prior to 01.07.2018 ."

  • "The principles of parity require that employees claiming equal treatment must be similarly situated in all material aspects , which is not the case here."

No Reversal: Appeal Echoes Precedent, Sets Service Precedent

On 21.04.2026 , the Bench dismissed the appeal "in terms of the order dated 13.03.2026 passed in WA No. 193/2026," finding no perversity in the Single Judge's analysis.

This reinforces Panchayat-State divides, barring pre-absorption benefits for thousands of absorbed Shiksha Karmis. Future claims must navigate absorption clauses strictly, prioritizing identical service genealogy for parity. While closing doors for these appellants, it clarifies policy intent amid Chhattisgarh's rural education integration efforts.