Summary
Employees who accepted IFCI’s 2008 voluntary-retirement package sought enhanced pension using later adopted pay scales. The Court held that the scheme had to be applied as a complete package, including its final-settlement restrictions. Pension regulations operated harmoniously with those terms and calculated benefits by reference to salary preceding retirement. Benefits under an earlier scheme or special treatment of a serving employee did not establish parity. The enhanced-pension relief was set aside.
Issues
- Whether later pay-scale adoption entitled VRS-2008 retirees to revised pension.
- Whether pension regulations or benefits granted under other circumstances displaced the scheme’s final-settlement terms.
Provisions considered
- Clauses 3.4, 7.2, 9.4, 9.11 and 9.12, IFCI Voluntary Retirement Scheme, 2008Pension formed part of the complete retirement package; salary at relieving and the express final-settlement and no-revision terms governed the claim. (¶¶ 12, 13, 14, 25, 29, 30, 36)
Held
- A voluntary-retirement scheme is a package whose terms must be strictly followed. Beneficiaries cannot import favourable terms from another scheme while retaining the benefits of the scheme they accepted. The specific clarification under VRS-2001 did not extend to VRS-2008. (¶¶ 21, 22, 23, 24, 25, 28)
- Incorporation of pension regulations did not detach pension from the scheme’s other terms. Calculation rested on average emoluments in the ten months before termination of employment; later pay arrangements for serving employees did not create a continuing right to recalculate this package. (¶¶ 25, 26, 27, 29, 30, 31, 32, 36)
- The single serving employee who remained on RBI scales under an exceptional arrangement was not similarly situated to VRS retirees. Repeated representations also did not cure the delay after prompt rejection, although the claim independently failed on its merits. (¶¶ 33, 34, 35)
Result
IFCI’s appeal was allowed and the Division Bench judgment granting enhanced-pension relief was set aside. The retirees’ claim to additional pension based on the later pay scales was rejected. No costs were imposed.