Supreme Court quashes LARSGESS Scheme benefits: Union of India vs. Bhagwan Deen (2022)

Date of the Judgment: April 05, 2022
Citation: (2022) INSC 394
Judges: Uday Umesh Lalit, J., S. Ravindra Bhat, J., Pamidighantam Sri Narasimha, J.
Can a government scheme that has been terminated still grant benefits to individuals? The Supreme Court of India recently addressed this question in a case concerning the LARSGESS Scheme of the Indian Railways. The court examined whether the Central Administrative Tribunal and the High Court of Delhi were correct in upholding claims made under the scheme after it had been terminated. The judgment was delivered by a three-judge bench comprising Justices Uday Umesh Lalit, S. Ravindra Bhat, and Pamidighantam Sri Narasimha, with Justice Uday Umesh Lalit authoring the opinion.

Case Background

The case involves an appeal by the Union of India against a decision of the High Court of Delhi, which had upheld an order by the Central Administrative Tribunal (CAT). The CAT had allowed an application by Bhagwan Deen and another respondent, granting them benefits under the LARSGESS Scheme. The Union of India challenged this decision, arguing that the scheme had been terminated and no further benefits could be claimed under it. The respondents had sought benefits under the LARSGESS Scheme, which was floated by the Indian Railways.

Timeline:

Legal Framework

The case primarily revolves around the interpretation and application of the LARSGESS Scheme, which was introduced by the Indian Railways. The scheme was intended to provide certain benefits to railway employees. However, the scheme was later terminated by the Union of India. The core legal issue is whether the respondents could claim benefits under the scheme after its termination. There are no specific sections of a statute mentioned in the judgment.

Arguments

Appellants’ Arguments (Union of India):

• The appellants argued that the Central Administrative Tribunal (CAT) was not justified in passing directions in favor of the respondents, as the LARSGESS Scheme had already been terminated.
• They contended that the High Court of Delhi erred in rejecting their challenge against the CAT’s decision.
• The Union of India relied on the fact that the Supreme Court had consistently refused to acknowledge any rights flowing from the LARSGESS Scheme after its termination.

Respondents’ Arguments (Bhagwan Deen & Anr.):

• The respondents had successfully argued before the Central Administrative Tribunal (CAT) that they were entitled to benefits under the LARSGESS Scheme.
• The respondents had successfully argued before the High Court of Delhi that the decision of the CAT should be upheld.

Submissions Table:

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame specific issues in the judgment. However, the core issue that the court addressed was:

• Whether the Central Administrative Tribunal (CAT) was justified in granting benefits under the LARSGESS Scheme after its termination, and whether the High Court of Delhi was correct in upholding the CAT’s decision.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues:

Authorities

The Supreme Court considered the following authorities:

• Punjab & Haryana High Court judgment dated 27.04.2016 in CWP No.7714 of 2016: The High Court had adversely commented on the LARSGESS Scheme.
• Dismissal of Special Leave Petition arising from the Punjab & Haryana High Court judgment: The Supreme Court had dismissed the SLP, indicating its agreement with the High Court’s view.
• Writ Petition (Civil) No.1407 of 2019 and Writ Petition (Civil) No.78 of 2021: The Supreme Court noted that it had consistently refused to acknowledge any rights flowing from the LARSGESS Scheme.

Authority Table:

Judgment

How each submission made by the Parties was treated by the Court?

How each authority was viewed by the Court?

• The Punjab & Haryana High Court judgment dated 27.04.2016 in CWP No.7714 of 2016 was viewed as an authority that had adversely commented on the LARSGESS Scheme, and the Supreme Court had agreed with this view by dismissing the SLP.
• The dismissal of the Special Leave Petition arising from the Punjab & Haryana High Court judgment was viewed as an affirmation of the High Court’s position by the Supreme Court.
• The consistent refusal to acknowledge any rights flowing from the LARSGESS Scheme in Writ Petition (Civil) No.1407 of 2019 and Writ Petition (Civil) No.78 of 2021 was viewed as a precedent for rejecting any claims under the scheme.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the fact that the LARSGESS Scheme had been terminated by the Union of India. The court emphasized that it had consistently refused to acknowledge any rights flowing from the scheme after its termination. This consistent stance was a major factor in the court’s decision to set aside the judgments of the Tribunal and the High Court.

Sentiment Analysis of Reasons:

Fact:Law Ratio:

Logical Reasoning:

The court did not consider alternative interpretations, as the termination of the scheme and the consistent stance of the Supreme Court were clear indicators that no benefits could be claimed under the scheme after its termination.

The court’s decision was based on the following reasons:

• The LARSGESS Scheme was terminated by the Union of India.
• The Supreme Court had consistently refused to accept, acknowledge, and uphold any right flowing from the provisions of the Scheme.
• The Tribunal was not justified in passing directions in the instant matter.
• The High Court was in error in rejecting the challenge raised by the appellants.

“This Court has since then consistently refused to accept, acknowledge and uphold any right flowing from the provisions of the Scheme.”

“Viewed thus, the Tribunal was not justified in passing directions in the instant matter and the High Court was in error in rejecting the challenge raised by the appellants.”

“We, therefore, allow this appeal, set-aside the view taken by the Tribunal and the High Court and dismiss Original Application No.4320 of 2014.”

There were no majority or minority opinions as it was a unanimous decision by the three-judge bench.

Key Takeaways

• Terminated government schemes do not grant any further benefits.
• Courts will not uphold claims made under terminated schemes.
• The Supreme Court’s consistent stance on a matter will be a key factor in future cases.

The decision has significant implications for similar cases involving terminated government schemes. It reinforces the principle that once a scheme is terminated, no further rights or benefits can be claimed under it. This will likely impact future cases where individuals seek benefits under previously terminated schemes.

Directions

The Supreme Court directed the appellants to deposit a sum of Rs.25,000/- towards costs for the respondents within three weeks from the date of the judgment. The amount is to be recovered from the concerned officials responsible for the delay in filing the matter.

Development of Law

The ratio decidendi of the case is that once a government scheme is terminated, no further benefits can be claimed under it. This judgment reinforces the existing legal position that terminated schemes do not create any further rights or obligations. There is no change in the previous position of law, but it re-emphasizes the court’s consistent stance on terminated schemes.

Conclusion

The Supreme Court allowed the appeal filed by the Union of India, setting aside the judgments of the Central Administrative Tribunal and the High Court of Delhi. The court held that the respondents were not entitled to any benefits under the LARSGESS Scheme, as the scheme had been terminated. The decision reinforces the principle that terminated government schemes do not grant any further benefits, and courts will not uphold claims made under such schemes.

Category

Parent Category: Service Law
Child Category: LARSGESS Scheme
Parent Category: Government Schemes
Child Category: Termination of Schemes

FAQ

Q: What does this judgment mean for individuals who were hoping to benefit from the LARSGESS Scheme?
A: This judgment means that individuals who were hoping to benefit from the LARSGESS Scheme after its termination will not be able to claim any such benefits. The Supreme Court has made it clear that terminated schemes do not grant any further rights or benefits.

Q: Can any government scheme be terminated without providing benefits to those who were eligible?
A: Yes, this judgment reinforces the idea that once a government scheme is terminated, no further benefits can be claimed under it. The government has the right to terminate schemes, and this decision upholds that right.

Q: What should people do if they are unsure about the validity of a government scheme?
A: If you are unsure about the validity of a government scheme, it is best to consult a legal professional or review official government notifications and gazettes. This will help you understand the current status of the scheme and whether you are eligible for any benefits.