Delhi High Court Clarifies MACP Scheme Application in Cadre Restructuring Case
Court Rules Against Double Benefits for Employees Following Hierarchical Upgradation
In a significant judgment delivered on October 9, 2025, the Delhi High Court, comprising Justices Navin Chawla and Madhu Jain, addressed the application of the Modified Assured Career Progression (MACP) Scheme in the context of cadre restructuring within the Defence Establishments. The court ruled that placement in a higher grade following cadre bifurcation based on seniority should be counted as upgradation, thus disentitling employees from MACP benefits.
The case, Union of India v. Satyvir Singh, involved two petitions challenging the orders of the Central Administrative Tribunal (CAT), which had previously ruled in favor of employees claiming MACP benefits despite their placement in higher grades following cadre restructuring. The restructuring stemmed from recommendations of the Sixth Central Pay Commission, which led to the division of the Highly Skilled grade into two sub-grades: Highly Skilled Grade-I and Highly Skilled Grade-II.
The petitioners, including Satyvir Singh and others, argued that their placement in Highly Skilled Grade-I was merely a re-designation rather than a promotion or upgradation. They contended that this placement should not affect their entitlement to MACP benefits, which are designed to provide financial upgradations to employees who remain stagnant in the same grade pay for extended periods.
The court, however, disagreed with the petitioners' interpretation, emphasizing that the restructuring created distinct hierarchical grades with different grade pays, and the placement was determined by seniority. The judgment underscored that such placement constitutes an upgradation, which should be accounted for under the MACP Scheme to prevent granting double benefits. The court cited previous Supreme Court rulings, including Bharat Sanchar Nigam Limited v. R. Santhakumari Velusamy, to support its decision.
Justice Navin Chawla, delivering the oral judgment, noted that granting MACP benefits in this context would contravene the scheme's objective of providing relief against stagnation, as the employees had already been advanced to a higher grade pay. The court reaffirmed the principle that any advancement in grade pay must be considered when calculating MACP entitlements.
Ultimately, the court set aside the CAT's order in O.A. No.4101/2012, which had favored the respondents, while upholding the order in O.A. No.778/2014, which had denied MACP benefits. The decision clarifies the legal position regarding cadre restructuring and its implications for MACP entitlements, reinforcing the scheme's purpose of alleviating stagnation without conferring double advantages.
Bottom Line:
Placement in Highly Skilled Grade-I following cadre bifurcation based on seniority constitutes upgradation, thereby disentitling employees from benefits under the Modified Assured Career Progression (MACP) Scheme.
Statutory provision(s): Modified Assured Career Progression Scheme (MACP), Sixth Central Pay Commission recommendations, Office Memorandum No.35034/1/97-Estt.(D) dated 18.07.2001, CCS (Revised Pay) Rules, 2008.
Union of India v. Satyvir Singh, (Delhi)(DB) : Law Finder Doc Id # 2795413
