The Supreme Court held that the appellants, whose services in the work-charged establishment were regularized, are entitled to benefits under the Proficiency Step-up Scheme, 1988. It reversed the High Court's judgment that denied such benefits, holding that similar benefits were already granted to identically placed employees.

1. Background (Paras 1–4)

• Fact: Appeals were filed against the Punjab & Haryana High Court judgment dismissing the appellants' writ petitions seeking benefits under the Proficiency Step-up Scheme, 1988.
• Observation: Appellants argued discriminatory denial of benefits to work-charged employees despite the Policy Circular (1996) stating that past service would qualify for pensionary and other benefits.

2. Key Arguments by Counsel (Paras 5–6)

• For Appellants:
  • Appellants argued hostile discrimination under Article 14, as similarly situated employees were granted benefits.
  • Circulars and court orders confirmed that work-charged service qualifies for Proficiency Step-up benefits.
• For State:
  • State opposed claims, arguing benefits were granted only to those covered by judicial orders.

3. Judicial History and Analysis (Paras 7–12)

• Policy Interpretation:
  • The 1996 Circular mandated the counting of work-charged service as qualifying service for pension and related benefits.
  • Earlier High Court and Tribunal decisions affirmed the inclusion of work-charged service for Proficiency Step-up benefits.
• Error in High Court Decision:
  • The High Court wrongly equated the Proficiency Step-up Scheme, 1988, with the Assured Career Progression Scheme (1998), leading to denial of benefits.
• Precedents:
  • Reliance placed on multiple judgments confirming the eligibility of work-charged employees for such benefits.

4. Supreme Court's Conclusion (Paras 13–16)

• Held:
  • Appellants are entitled to count their work-charged service for benefits under the Proficiency Step-up Scheme, 1988.
  • Monetary benefits are to be disbursed within six months.
• Ratio:
  • Discrimination against similarly placed employees violates Article 14 of the Constitution.

Acts, Sections, and Legal Principles Discussed

1. Proficiency Step-up Scheme, 1988: Government policy for financial advancement based on qualifying service.
2. Article 14, Constitution of India: Right to equality and prohibition of discriminatory treatment.
3. Policy Circular (13th March 1996): Inclusion of work-charged service as qualifying service for pensionary benefits.

Subjects: Service Law – Benefits under Proficiency Step-up Scheme, 1988

• Service Law, Proficiency Step-up Scheme, Work-charged Employees, Article 14, Discrimination, Pensionary Benefits.