Delhi High Court Quashes Committee-Based Adjudication for Teacher Salary Claims

Court Asserts Judicial Functions Cannot Be Delegated to Committees; Mandates Fresh Consideration by Roster Bench

In a significant judgment, the Delhi High Court has set aside the earlier decision of a Single Judge to constitute committees at the zonal and central levels for adjudicating claims related to salary arrears and benefits of teachers in private unaided schools. The judgment, delivered by a Division Bench comprising Justices Subramonium Prasad and Vimal Kumar Yadav, underscores that judicial functions, particularly adjudicatory roles, cannot be relegated to committees and must remain within the purview of the judiciary.

The case, titled Renu Arora v. St. Margaret Senior Secondary School, revolved around claims for payment of salaries as per the 6th and 7th Central Pay Commission (CPC) recommendations. Teachers from various private unaided schools in Delhi had petitioned for their salaries to be aligned with those of their counterparts in government schools, as mandated by Section 10 of the Delhi School Education Act, 1973.

The Single Judge had initially ruled in favor of the teachers, acknowledging the mandatory nature of Section 10 and dismissing objections related to delay and financial constraints faced by the schools. However, the decision to form committees for further adjudication of claims was met with resistance, prompting appeals from both the teachers and the schools.

The Division Bench, in its judgment, emphasized that while courts can appoint committees for fact-finding purposes, these bodies cannot be vested with judicial decision-making powers. The judgment cited precedents from the Supreme Court to bolster its stance that adjudicatory functions are inalienable and must be exercised by judges.

Moreover, the Bench noted that several issues raised by the schools, such as the eligibility of teachers and the schools' rights to adjust fee structures, were not adequately addressed in the initial judgment. It directed that the matter be remanded to the Roster Bench for a comprehensive reassessment, ensuring that all arguments and evidence are duly considered.

This decision reaffirms the judiciary's pivotal role in adjudicating disputes and highlights the limitations on the delegation of judicial powers. The High Court's ruling is expected to have significant implications for the administration of education laws in Delhi, particularly concerning the financial and operational autonomy of private educational institutions.

Bottom Line:

Courts cannot delegate judicial functions to committees for adjudication; Committees can only serve as fact-finding bodies to assist in adjudication.

Statutory provision(s): Constitution of India Article 226, Delhi School Education Act, 1973 Section 10, 17, 18.

Renu Arora v. St. Margaret Senior Secondary School, (Delhi)(DB) : Law Finder Doc Id # 2799936