1. Both these writ petitions challenge the orders passed by the Tribunal. In SBCWP No.6132/02, Tribunal to the extent denied that benefit of selection scale to the petitioner the period of three years as provided in Article 137 of the Limitation Act, 1963. Learned counsel for the petitioner has argued that judgment of the Tribunal has thus restricted claim of the petitioner only for the period of three years from the date of filing of the application whereas Tribunal started functioning in the year 1995 and the application in SBCWP No.6132/02 was filed in 1998 and in SBCWP No.4437/02 in 1999. Learned counsel for petitioner submitted that even if the Government for its employees issued circular dated 25/1/1992 providing for grant of selection scale on completion of 9 years for its inability to grant them promotion and with a view to remove the stagnation however, Non-Government Educational Institutions did not grant such benefits not only to petitioners but also other employees working in different Institutions. When Government was approached by the institution as well as effected employees, Government vide its circular dated 17/11/1997 clarified that selection grade will not be available to the teachers available in the Non-Government Educational Institutions. Petitioner had to then file application before the Tribunal. This matter ultimately was referred to the Full Bench of this Court owing to conflict opinion as per reference made by the Division Bench. Full Bench of this Court in S.R. Higher Secondary School & Anr. v. Raj Non-Government Educational Institutions Tribunal, Jaipur & 23 Others, 2002(3) WLC (Raj.) 586 : [2003(4) SLR 33 (Raj.)] held that as per Section 29 of the Rajasthan Non- Government Educational Institutions, Act, 1989 and Rule 34 of the Non- Government Educational Institutions (Recognition, Grant-in-aid and Service Conditions, etc.) Rules, 1993, the teachers working even in the Government institutions would also be entitled to selection scale as was payable to the teachers working in the Government schools. State Government approached the Supreme Court by way of Special Leave to Petition in which proceedings, Non- Government Educational Institutions were also represented. Supreme Court in State of Rajasthan and another v. Senior Higher Secondary School, Lachhmangarh and others, (2005) 10 SCC 346 upheld the Division Bench judgment but in so far as claim of the non-government educational institutions for grant-in-aid against payment of selection grade is concerned, it was directed that it could not be claimed as a matter of right but opportunity was given to such Institutions to represent the government. Learned counsel cited the judgment of this Court in The Managing Committee, S.P.R. Saharia Senior Secondary School, Kaladera Shri Ganga Singh Shekhawat & Ors., SBCWP No.4697/2000 decided on 15/4/2002 and argued that co-ordinate bench of this Court in the aforesaid judgment has taken the view that even if Section 21 of the Act of 1989 does not provide for time limit for filing application before the Tribunal, there can be no manner of doubt that the application has to be moved by an employee, who is aggrieved by any act of the employer relating to service conditions, within reasonable time. What shall be the reasonable time has to be ascertained by the courts in the given facts and circumstances of a case. Unless and until the facts and circumstances are alleged by the party who has raised the question of limitation, that question cannot be gone into because the reasonableness of time will depend upon the factual matrix of each and every case. Simply because the application has been moved after a long delay that itself can not be a ground for refusal, unless it is established that the period taken by the party before approaching the court was unreasonable or without any just cause.

2. Shri Rajesh Jain and Shri Deepak Asopa, learned counsel for the respondents have opposed the writ petitions and s