Randhir Singh v Union of India
Rule established
The principle of 'equal pay for equal work,' though not expressly named as a fundamental right in Part III, is deducible from the equality guarantees under Articles 14 and 16, read with the Directive Principle in Article 39(d); persons performing the same or substantially similar duties, functions, and responsibilities are entitled to the same pay scale, absent a rational justification for differentiation.
Facts
- Randhir Singh, a driver-constable in the Delhi Police force, challenged the disparity in pay scale between his category of employees and other comparable categories performing substantially similar duties within the police and allied services
- He contended that this pay disparity, without adequate justification, violated the constitutional guarantee of equality
Issue
- Whether the principle of "equal pay for equal work," a Directive Principle under Article 39(d), can be judicially enforced as flowing from the fundamental rights of equality under Articles 14 and 16.
Held
- The Supreme Court held that although "equal pay for equal work" is expressed as a Directive Principle in Article 39(d), and Directive Principles are not directly enforceable, this particular principle can be read into and enforced through Articles 14 and 16, which guarantee equality before law and equality of opportunity in public employment
- Where employees perform substantially similar duties, functions, and responsibilities, requiring similar skill, effort, and responsibility, they are entitled to be paid on par, and unjustified disparity in pay scales amounts to discrimination
- The state, if it seeks to justify differential pay for what appears to be substantially similar work, must demonstrate a rational basis for the distinction, such as differences in qualifications, nature of work, or responsibility actually involved
- On the facts, the Court found the disparity in pay for the petitioner's category was not justified, and directed appropriate relief
Ratio Decidendi
The principle of equal pay for equal work, while framed as a Directive Principle under Article 39(d), is enforceable through Articles 14 and 16 as an emanation of the constitutional equality guarantee; employees performing substantially similar duties and responsibilities are entitled to parity in pay, subject to the state's ability to justify differentiation on a rational basis.
How to use it in an exam
- The foundational case establishing equal pay for equal work as a judicially enforceable principle in Indian constitutional and labour law, essential background for both Labour Law and Constitutional Law papers
- Pair with Mackinnon Mackenzie & Co. v Audrey D'Costa (1987) for the specific statutory application under the Equal Remuneration Act, 1976
- Key line: Directive Principles can gain enforceable teeth when read together with a relevant fundamental right, and this case is the classic illustration in the wage context
Source
Source: AIR 1982 SC 879; foundational authority establishing equal pay for equal work as a constitutional principle, cross-verify citation before exam use
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.