Supreme Court clarifies the status of Field Supervisors as Teachers: Registrar, Orissa University of Agriculture & Technology vs. Upendra Nath Patra & Anr. (23 April 2018)

Date of the Judgment: 23 April 2018
Citation: (2018) INSC 327
Judges: S.A. Bobde, J., L. Nageswara Rao, J.

Can a university employee, specifically a Field Supervisor, be considered a teacher and be entitled to the benefits of a teacher? The Supreme Court of India recently addressed this question, focusing on the interpretation of the Orissa University of Agriculture and Technology’s statutes. This case revolves around the classification of employees and their entitlement to teacher status, impacting the rights and benefits of the employees. The judgment was delivered by a bench comprising Justices S.A. Bobde and L. Nageswara Rao, with the majority opinion authored by Justice L. Nageswara Rao.

Case Background

Shri Upendra Nath Patra was appointed as a Field Supervisor at the Orissa University of Agriculture & Technology on 10th February 1972. Shri Binod Chandra Mahanti was initially appointed as a Statistical Assistant on 11th December 1979, and later transferred to the post of Field Supervisor. The dispute arose when both individuals sought to be recognized as teachers, entitling them to the benefits associated with that designation.

Upendra Nath Patra filed OJC No. 2412 of 1985, seeking a declaration that his post of Field Supervisor should be treated as equivalent to that of a teacher. This was partly based on a letter dated 26th March 1981, from the University to the Government, which stated that certain posts, including Field Supervisor, should be treated as teachers if the incumbents were post-graduates. The High Court initially ruled in his favor. However, Binod Chandra Mahanti’s OJC No. 3390 of 1990, seeking similar relief, was dismissed by another division bench of the High Court, creating a conflict in judicial opinions.

Timeline

Course of Proceedings

The High Court of Orissa initially ruled in favor of Upendra Nath Patra in OJC No. 2412 of 1985, declaring the post of Field Supervisor equivalent to that of a teacher. This decision relied on an earlier judgment and a letter from the University. However, a different division bench dismissed Binod Chandra Mahanti’s OJC No. 3390 of 1990, stating that the post of Field Supervisor could not be considered a teaching post.

Due to these conflicting judgments, Civil Review No. 102 of 1993 and Civil Review No. 106 of 1992 were referred to a larger bench. The full bench of the Orissa High Court upheld the judgment in OJC No. 2412 of 1985 and overruled the judgment in OJC No. 3390 of 1990. This led to the current appeal before the Supreme Court.

Legal Framework

The Supreme Court examined the relevant provisions of the Orissa University of Agriculture and Technology Act, 1965, specifically Section 2(10) and Statute 19 of the Statutes of the University.

Section 2(10) of the Act defines a “Teacher” as:

“a person appointed or recognized by the University for the purpose of imparting instruction or conducting and guiding research or extension educational programmes and includes a person who may be declared by the Statute to be a teacher.”

Statute 19 of the Statutes classifies teachers into three categories:

• Category I: Persons appointed for imparting education.
• Category II: Persons appointed for conducting or guiding research or extension educational programs.
• Category III: Persons declared by the Statutes as teachers.

Statute 19(3) further states that posts held by teachers in Category II and Category III may be declared by the University, with the prior approval of the Board, as equivalent to the posts of Professor, Reader, Lecturer Grade-I, or Lecturer Grade-II.

Arguments

The Appellants (University) contended that the Registrar’s order dated 16th March 1979, declaring Field Supervisors as teachers, was only for the limited purpose of elections and that the Registrar lacked the authority to issue such an order. The University also argued that the Academic Council did not approve extending UGC benefits to Field Supervisors as they did not possess the requisite qualifications. They relied on the fact that the Board of Management had accepted the Academic Council’s resolution.

The Respondents (Upendra Nath Patra and Binod Chandra Mahanti) argued that the order dated 16th March 1979, declaring Field Supervisors as teachers, was valid and had not been withdrawn. They also relied on the University’s letter dated 26th March 1981, to the Government, which stated that Field Supervisors should be treated as teachers if they were post-graduates. They contended that the declaration of a teacher for one purpose should hold good for all other purposes.

The Respondents also relied on the judgment in Rajendra Prasad Mishra & Ors. v. Orissa University of Agriculture and Technology & Anr. where the High Court had held that the post of Senior Research Assistant should be treated as a post of Teacher falling under category II of Statute 19 (1) of the Statutes.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame issues in a separate section. However, the core issue was whether Field Supervisors could be treated as teachers under the Orissa University of Agriculture and Technology Act, 1965 and its statutes.

Treatment of the Issue by the Court

Authorities

The Supreme Court considered the following authorities:

Judgment

The Supreme Court analyzed the authorities and submissions as follows:

✓ The Court relied on the judgment in Rajendra Prasad Mishra & Ors. v. Orissa University of Agriculture and Technology & Anr.* where the High Court had held that the post of Senior Research Assistant should be treated as a post of Teacher falling under category II of Statute 19 (1) of the Statutes.

✓ The Court cited Sanjay Singh & Anr. v. U.P. Public Service Commission, Allahabad & Anr. [(2007) 3 SCC 720] to emphasize that the relief granted is not a natural consequence of the ratio of the judgment.

✓ The Court interpreted Section 2(10) of the Orissa University of Agriculture and Technology Act, 1965 to define a teacher as someone appointed for imparting instruction or guiding research, including those declared by statute.

✓ The Court also interpreted Statute 19 of the Statutes of the Orissa University of Agriculture and Technology, 1966 to classify teachers into three categories. The Court clarified that posts under Category II and Category III could be declared equivalent to teaching posts by the University with the Board’s approval.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the following factors:

• The court emphasized that the order dated 16th March 1979, which declared Field Supervisors as teachers, had not been withdrawn or rescinded.
• The court also took into account the University’s letter dated 26th March 1981, which supported the claim that Field Supervisors should be treated as teachers.
• The court interpreted Statute 19 of the Statutes, clarifying that a declaration was required for those in Category II and Category III to be treated as teachers, and that the full bench of the High Court had erred in its interpretation.
• The court was also sympathetic to the fact that the Respondents had been fighting for their rights for nearly 30 years.

The Court’s reasoning was a blend of factual analysis (the existence and validity of the 1979 order and 1981 letter) and legal interpretation (of Statute 19). The legal interpretation played a slightly more significant role in the court’s decision.

Logical Reasoning

The Court rejected the interpretation of the full bench of the High Court that Statute 19(3) does not apply to persons falling in Category II. The Court held that a declaration is required for persons falling under both Category II and Category III to be treated as teachers. The Court also rejected the University’s argument that the Registrar’s order was for a limited purpose and that the Registrar lacked the authority to issue such an order.

The Court’s decision was based on a plain reading of Statute 19, which clearly states that a declaration by the University with the prior approval of the Board is required to treat a Field Supervisor as a Teacher.

The Court quoted from the judgment:

• “A plain reading of Statute 19 would show that Field Supervisors who fall in Category II claiming to be Teachers have to be declared by the University as Teachers.”
• “We are of the opinion that a post of Field Supervisor can be treated as a Teacher only after a declaration by the University with the prior approval of the Board and not otherwise.”
• “We also accept the logic of the Division Bench of the High Court in Upendra Nath Partra’s case (supra) that the declaration of a Teacher for one purpose will hold good for the others too.”

There were no dissenting opinions in this case.

Key Takeaways

• Field Supervisors can be treated as teachers if declared by the University with the prior approval of the Board.
• A declaration of a teacher for one purpose is valid for all other purposes.
• Universities must follow the correct procedure for declaring posts equivalent to teaching posts.
• The judgment clarifies the interpretation of Statute 19 of the Statutes of Orissa University of Agriculture and Technology.

Directions

The Supreme Court directed that the Respondents should be given all consequential benefits of being treated as teachers. The Court also clarified that the University could withdraw the proceeding dated 16th March 1979, but that such withdrawal would not affect the Respondents’ entitlement to benefits.

Development of Law

The ratio decidendi of this case is that for a Field Supervisor to be considered a Teacher, a declaration by the University with the prior approval of the Board is necessary. This judgment clarifies the interpretation of Statute 19 of the Statutes of the Orissa University of Agriculture and Technology, 1966 and overrules the interpretation of the full bench of the High Court.

Conclusion

The Supreme Court disposed of the appeals, holding that Field Supervisors can be treated as teachers if declared by the University with the prior approval of the Board. The Court upheld the validity of the Registrar’s order dated 16th March 1979, and the University’s letter dated 26th March 1981. The judgment clarifies the interpretation of Statute 19 of the Statutes and ensures that the Respondents receive the benefits of being treated as teachers.