Summary
Manipur could not justify a lower pension revision for pre-1996 retirees solely on financial constraints where existing pensioners formed one class and revision addressed increased living costs. The retirement-date distinction had no rational nexus to that object and violated Article 14. Applying D.S. Nakara, the Court distinguished cases concerning new pension benefits or different classes and restored the direction for parity in revision.
Issues
- Whether financial constraints alone justified different rates of revision for pre-1996 and post-1996 pensioners under the existing pension regime.
Provisions considered
- Article 14, Constitution of IndiaThe cut-off dividing similarly situated existing pensioners lacked a rational nexus to the cost-of-living object of pension revision and was discriminatory. (¶¶ 7.1–7.3, 8–8.1)
Held
- The State relied solely on financial constraints. Pensioners governed by the applicable pension rules formed a homogeneous class, and increased living costs affected both retirement groups. (¶¶ 7.1–7.3, 8.1)
- D.S. Nakara governed this revision of existing pension benefits. Authorities involving new schemes, new benefits or different classes did not justify the impugned distinction. (¶¶ 7.4–7.9, 8.1–9)
- A retirement-date classification must satisfy intelligible differentia and rational nexus requirements; the distinction here did not further the stated object of revision. (¶ 8)
Result
Appeal allowed; Division Bench judgment set aside and Single Judge judgment restored. Pre-1996 retirees held entitled to pension revision at par with post-1996 retirees, with arrears payable within three months. No costs.