Panchayat & Rural Development Department & Ors. Vs. Santosh Kumar Shrivastava,
[Civil Appeal arising out of SLP (C) No. 21625 of 2025], delivered by Justice Sanjay Karol (with Justice Prashant Kumar Mishra concurring) on 22 September 2025.
1️⃣ Main Issue Before the Court
The Supreme Court considered the legal question:
Whether failure to vacate government accommodation after retirement can justify withholding payment of pension, gratuity, or other retiral dues.
2️⃣ Facts in Brief
Respondent (Santosh Kumar Shrivastava) was a government employee who retired on 30 June 2013.
His pension and gratuity were not released for almost three years.
The Department justified this delay by alleging that he did not vacate his official residence until 31 August 2015.
When his dues were finally released, deductions were made towards penal house rent (₹1,56,187) and excess salary payment (₹1,46,466).
3️⃣ Findings of the High Court
The Single Judge held that withholding pension and gratuity merely because of pending recovery or non-vacation of residence was illegal.
Ordered refund of deductions with 6% interest.
The Division Bench upheld this order, leading to the present appeal.
4️⃣ Supreme Court’s Reasoning
(a) Pension and Gratuity Are Legal Rights
The Court reaffirmed that pension, gratuity, and retiral dues are not bounties but vested rights earned through service.
Cited precedents:
PEPSU RTC v. Mangal Singh (2011) 11 SCC 702
U.P. Roadways Retired Officials Assn. v. State of U.P. (2024) 9 SCC 331
“Payment of retiral dues is a matter of right, not a charity.”
(b) No Justification to Withhold Dues
The Department’s reason — that the employee did not vacate government accommodation — has no legal nexus with withholding pension.
The right to pension arises from long service;
the right to official residence arises from holding a specific post.
These are two distinct and independent matters.
“The latter (residence) cannot obstruct or defeat the former (pension).”
(c) Illegal Recovery of Excess Salary
The Court held that the recovery of alleged excess pay after retirement was impermissible.
Referred to Syed Abdul Qadir v. State of Bihar (2009) 3 SCC 475, which held that:
Recovery cannot be made if excess payment was not due to employee’s fraud or misrepresentation, and
If the employer made a mistake, the employee should not be penalized.
The respondent had not committed any fraud; therefore, the recovery was unjustified.
(d) Department’s Conduct Criticized
The Court noted that the Department delayed payments for over three years without valid justification.
The State acted unreasonably and unfairly, holding back pension as a “sword over the retiree’s head.”
(e) Interest Award Justified
Since the delay was solely due to the Department,
the Court upheld the direction to pay 6% interest on the delayed amounts.
The award of interest was equitable and legally proper.
5️⃣ Conclusion
Appeal dismissed.
The respondent was entitled to refund with 6% interest.
No order as to costs.
📘 ESSENCE OF THE REASONS (ENGLISH SUMMARY)
Pension and gratuity are statutory rights, not discretionary benefits.
Non-vacation of government quarters cannot justify withholding such dues.
Recovery of excess payment not allowed when employee acted in good faith.
Department’s delay was arbitrary and unfair.
Award of 6% interest on delayed payment upheld.
Appeal dismissed — High Court order sustained
TELUGU