Supreme Court upholds Gauhati HC order directing Nagaland to ensure salary parity for RMSA teachers

Supreme Court: In a matter concerning pay parity for teachers employed under the Rashtriya Madhyamik Shiksha Abhiyan (‘RMSA’), the Division Bench of Dipankar Datta and K. Vinod Chandra, JJ. declined to interfere with a judgment passed by the Gauhati High Court, wherein the Court directed the Nagaland State Government to pay salaries to a batch of teachers employed under RMSA in parity with their counterparts.

In December 2013, RMSA advertised 951 posts for teachers and sports instructors, and by 2015, 627 posts for Graduate Teachers were sanctioned in the pay band of ₹9,300—34,800 with grade pay of ₹4,200. Following the recruitment process, 639 candidates were appointed on a contractual basis in two phases, 528 in November 2015 and 111 in May 2016, at a fixed monthly pay of ₹31,315. All appointees signed bonds acknowledging the contractual nature of their employment.

In 2018, after the merger of Sarva Shiksha Abhiyan (‘SSA’) , RMSA, and Teacher Education (‘TE’) under Samagra Shiksha, the salary of Secondary School teachers was fixed at ₹25,000. Subsequently, the State Government issued Office Memoranda reducing the petitioners’ salaries and warning of disciplinary action, prompting them to approach the High Court.

While a Single Judge set aside the salary reduction orders in 2020, it declined direct payment as per the sanctioned pay band. The petitioners then appealed to a Division Bench.

On 16-03-2022, the Division Bench ruled in the petitioners’ favour, directing the State to grant them the pay scale of ₹9,300—34,800 with grade pay of ₹4,200. The High Court held that the petitioners were “equally placed in all respects” with other similarly appointed teachers and upheld the principle of equal pay for equal work. It observed that the State could not treat two classes of teachers differently when their duties, qualifications, and recruitment processes were identical.