State of Bihar's appeal succeeds as court upholds estoppel against late pension claims following EPF scheme acceptance.
In a significant judgment, the Jharkhand High Court ruled in favor of the State of Bihar, overturning a previous decision that had granted pension benefits to the widow of a deceased employee who had retired in 1991. The Division Bench, comprising Justices Sujit Narayan Prasad and Rajesh Kumar, delivered the verdict on November 6, 2025, in the case of State of Bihar v. Savitri Devi, setting aside the 2013 judgment by a Single Judge.
The original writ petitioner, a Class-IV employee, had served in the Food Supply and Commerce Department of the Bihar State Government before being deputed to the Bihar State Food and Civil Supplies Corporation. Upon his retirement in 1991, he accepted terminal benefits under the Employees' Provident Fund (EPF) scheme. The court observed that the petitioner did not object to the EPF scheme during his service tenure or at retirement and had accepted the scheme's benefits.
The court emphasized the principle of estoppel, asserting that the petitioner, having accepted the EPF benefits, could not later claim pension benefits after a significant delay of 16 years post-retirement. The Bench highlighted that pension is a constitutional right under Article 300-A of the Indian Constitution, yet it is contingent on the individual's employment status and the benefits they choose to accept during their service.
The judgment underscored that claims for pension made after such a prolonged period, especially when alternate benefits have been accepted, are untenable. The court's decision reaffirms the legal principle that employees who opt for alternate benefit schemes like EPF cannot later retract their decision to claim pension benefits.
This decision reflects the judiciary's stance on balancing constitutional rights with practical implications of delayed claims and acceptance of alternate benefits. The ruling serves as a crucial precedent for similar cases where pension claims are made after extensive delays.
Bottom Line:
Pension is a constitutional right to property; however, employees who have voluntarily accepted benefits under alternate schemes like EPF cannot claim pension benefits later, especially after a significant delay without objections during service.
Statutory provision(s): Article 300-A of the Constitution of India, Employees' Provident Funds and Miscellaneous Provisions Act, 1952, Order XLI Rule 27 of CPC.
State of Bihar v. Savitri Devi, (Jharkhand)(DB) : Law Finder Doc Id # 2805071
