Does Railway Training Count as Service for MACP?

Railway employees often face uncertainty when calculating their service length for financial upgradations under the Modified Assured Career Progression (MACP) Scheme. A common question arises: whether training period will be counted as regular service for granting MACP in railway? This issue impacts promotions, increments, and arrears, especially for those who underwent initial or in-service training post-appointment.

In this post, we break down the legal position, drawing from railway manuals, office memorandums (OMs), and court rulings. While this provides general insights, consult a legal expert for your specific case, as outcomes may vary based on individual circumstances.

Main Legal Finding: Yes, In-Service Training Typically Counts

Generally, yes—the training period qualifies as regular service for MACP eligibility in the railway department, provided it is in-service training undergone during the service period as per appointment conditions and relevant railway manuals. Courts have consistently held that such training cannot be excluded from the length of service for financial upgradation under the Assured Career Progression (ACP) Scheme (predecessor to MACP), and the same principles apply to MACP. 2017 0 Supreme(Ori) 174

Key points include:- In-service training periods, as stipulated in job advertisements and appointment letters, count towards ACP/MACP benefits.- The MACP Scheme defines 'regular service' starting from joining a direct entry grade on a regular basis, excluding only ad-hoc/contract service or pre-appointment training—implying post-joining training is reckonable. 2023 0 Supreme(Del) 2195 2017 0 Supreme(Gau) 795- Railway-specific rulings affirm this, referencing the Indian Railway Establishment Manual (IREM) and circulars. 2017 0 Supreme(Ori) 174

Understanding MACP and Regular Service Definition

The MACP Scheme, introduced via Railway Board’s RBE No. 101/2009 (OM dated 19.05.2009), grants financial upgradation after 10, 20, and 30 years of regular service, differing slightly from ACP's 12/24/36 years but retaining core logic.

What Constitutes 'Regular Service'?

Service rendered on adhoc/contract basis before regular appointment on pre-appointment training shall not be taken into reckoning. 2023 0 Supreme(Del) 2195 2017 0 Supreme(Gau) 795 This clause explicitly excludes pre-appointment phases but is silent on in-service training, allowing it to form part of continuous regular service post-joining.

Tribunals have reinforced this: Treating of training period as regular service for the purpose of granting ACP/MACP is no more a res integra. This Tribunal held the same view in OA No. 763 of 2014. 2025 Supreme(Online)(CAT) 3400 In another case, a trainee ASM appointed in 1984 successfully claimed 3rd MACP by including training as continuous service, with the Tribunal quashing denial and directing grant from 30.04.2020 with arrears. 2025 Supreme(Online)(CAT) 3400

Landmark Railway Rulings on Training for Career Progression

A pivotal railway case addressed denial of ACP upgradation by excluding training. The court ruled: the training obtained by the employees during their service period, as per the advertisement and appointment conditions, should be counted for the purpose of counting the length of service. It dismissed writs against the Tribunal's order, citing IREM, Apprenticeship Act, 1961, and circulars. 2017 0 Supreme(Ori) 174 This directly extends to MACP due to identical 'regular service' definitions.

Further support comes from: Training periods are to be considered as regular service for the purpose of granting MACP benefits. 2025 Supreme(Online)(CAT) 3400 In a promotion test context under Railway Protection Force Rules, 1987, the court held: The period of nine months' training undergone by the petitioner shall be included for the purpose of computing total period of service as on the date of notification. And, Period of training including in-service course shall be treated as duty for all purposes. 2010 0 Supreme(Ori) 573

Even non-railway analogies align: There is no specific provision which says that the period of training will not be counted as service, especially when the Department had been treating it as in-service training. 2016 0 Supreme(Ker) 228 This led to counting training for IAS promotion eligibility.

Distinctions: What Training Counts vs. Exclusions

Not all training qualifies. Key exceptions:- Pre-appointment Training: Explicitly excluded under MACP Clause 9. 2023 0 Supreme(Del) 2195 2017 0 Supreme(Gau) 795- Ad-hoc/Temporary Service: Prior regularization doesn't count, but probationary training post-joining does. 2017 0 Supreme(Ori) 174- Probation in New Posts: Continuous service counts post-probation for MACP. 2023 0 Supreme(Del) 2195

One counter-view rejected a 24-month training claim for MACP, but context suggests it was pre-regularization.

H C SHARMAVSM/O RAILWAYS

Additional affirmations: The training period is also considered as service and as such it will be counted for pension... there is no logical reason as to why the said period spent in training should not be counted for the purposes of granting other benefits. 2013 0 Supreme(UK) 332 2009 0 Supreme(All) 1231 In police contexts (analogous), training counted for promotional pay-scales, overriding contrary notes. 2009 0 Supreme(All) 1231

Practical Recommendations for Railway Employees

• Verify Documents: Check appointment letters, IREM, and MACP OMs (RBE 101/2009, 100/2012) against your training dates.
• File Representations: If denied, cite Tribunal/High Court orders like 2017 0 Supreme(Ori) 174 and 2025 Supreme(Online)(CAT) 3400, escalating to Central Administrative Tribunal (CAT) if needed.
• Claim Arrears: Compute from due dates (10/20/30 years), seeking interest for delays.

Railway Boards have clarified in cases: the period of in service training (imparted soon after recruitment) will have to be counted as ‘Service for all purposes (except for probation). 2008 0 Supreme(Ker) 277

Key Takeaways and Conclusion

In summary, in-service training in railways typically counts as regular service for MACP, backed by definitions excluding only pre-appointment/ad-hoc phases and affirmed by multiple rulings. 2017 0 Supreme(Ori) 174 2023 0 Supreme(Del) 2195 2025 Supreme(Online)(CAT) 3400

• Training per appointment conditions qualifies.
• Courts/Tribunals consistently include it for ACP/MACP.
• Exceptions are narrow: pre-appointment or ad-hoc only.

Railway employees should proactively document and claim these benefits. This is general information based on precedents—not personalized legal advice. For tailored guidance, approach CAT or a railway law specialist.

References:1. 2017 0 Supreme(Ori) 174: Core ruling on in-service training for ACP/MACP.2. 2023 0 Supreme(Del) 2195, 2017 0 Supreme(Gau) 795: MACP OM definitions.3. 2025 Supreme(Online)(CAT) 3400: Tribunal on training as regular service.4. Others integrated as cited.