The Supreme Court overturned the High Court and Central Administrative Tribunal's decisions that had granted technical personnel at the Indian Council of Agricultural Research (ICAR) the same benefit of two advance increments for acquiring a Ph.D. degree, a benefit originally intended only for scientists. The Court emphasized the distinction between the roles, rules, and benefits applicable to scientists and technical staff, dismissing the application of Article 14 (Right to Equality) in this context.

1. Background of the Case

The appellants, Indian Council of Agricultural Research (ICAR), challenged a High Court order that upheld the Central Administrative Tribunal's decision to extend the benefit of two advance increments for acquiring a Ph.D. degree to technical personnel, a benefit originally designed for scientists.

2. Nature of Services and Governing Rules

ICAR had established two distinct services—Agricultural Research Service (ARS) and Technical Service (TS)—each governed by separate service rules. The ARS, involving core research duties, offered incentives like advance increments for Ph.D. qualifications, whereas TS provided support in research and had no such financial incentives for Ph.D.s.

3. Key Contentions

The appellants argued that the Tribunal exceeded its jurisdiction by equating scientists with technical personnel, who, despite working towards a common objective, had different roles, recruitment processes, and pay scales. The extension of Study Leave Regulations to technical staff did not imply entitlement to the same financial benefits as scientists.

4. Court's Rationale

The Court noted that the technical personnel, although eligible for study leave to pursue a Ph.D., were not entitled to the advance increments as the scientists. The distinction between the roles was crucial, and Article 14 was deemed inapplicable since the benefits were attached to specific roles within a different cadre.

5. Conclusion

The Supreme Court allowed the appeal, setting aside the High Court and Tribunal orders. The application filed by the respondents for advance increments was dismissed, reaffirming ICAR’s policy distinctions between scientists and technical staff.