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Tripura HC Grants Five Advance Increments to PhD-Holding Prof

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The Tripura High Court has directed the state government to grant five advance increments to PhD-holding Assistant Professors and two to MPhil holders absorbed into the Higher Education Department, ordering payment of differential arrears within eight weeks.

the Tripura High Court has directed the state government to grant five non-compoundable advance increments to PhD holders and two advance increments to MPhil holders who acquired their higher qualifications while in service before being absorbed into the Assistant Professor cadre.

A Division Bench comprising Chief Justice M S Ramachandra Rao and Justice S Datta Purkayastha delivered the judgment while allowing two writ appeals filed by groups of Assistant Professors. The Bench also set aside a common judgment delivered by a single-judge Bench on July 6, 2026, which had earlier rejected their petitions.

The appellants were initially appointed as part-time contractual Post Graduate Teachers in degree colleges under the Higher Education Department. Following a decision of the state Council of Ministers in 2010, they were engaged as Post Graduate Teachers in the pay scale of Rs 5,310-24,000, with a grade pay of Rs 2,400.

Subsequently, following earlier directions issued by the High Court in 2021 and 2023, the state government introduced an absorption scheme in September 2022. Under the scheme, eligible Post Graduate Teachers were absorbed into the Assistant Professor cadre. The appellants were subsequently absorbed in 2022 and 2023.

However, a dispute emerged after the Higher Education Department issued a memorandum on August 4, 2023, granting only three advance increments to PhD holders and one increment to MPhil holders. The teachers challenged the decision, arguing that they were entitled to five and two increments, respectively, under the state’s notification dated December 27, 2019, read with the University Grants Commission (UGC) Regulations, 2018.

Opposing the appeals, the state government argued that the teachers had not been appointed through the Tripura Public Service Commission under the regular recruitment rules applicable to Assistant Professors. It maintained that their absorption through a special scheme justified granting them fewer increments than those available to other teachers.

Rejecting the government’s argument, the Division Bench observed that acquiring higher academic qualifications during service could not become a ground for denying teachers the financial benefits prescribed under the applicable rules. The court emphasised that obtaining PhD and MPhil qualifications enhances academic competence, research capabilities and the overall standards of higher education.

The Bench further held that teachers possessing the same qualifications within the Assistant Professor cadre should receive equal treatment, irrespective of whether they obtained their degrees before entering service or during their employment. Making a distinction based on the timing of qualification acquisition or the mode of entry into the cadre was considered arbitrary and discriminatory, violating Article 14 of the Constitution.

Accordingly, the High Court directed the state government to grant five non-compoundable advance increments to the appellants in WA 87 of 2026 and two such increments to the appellants in WA 88 of 2026, effective from their respective dates of absorption as Assistant Professors.

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The court also directed the government to pay the differential arrears within eight weeks. Additionally, any recovery of excess payments already made from the appellants must be stopped immediately, and amounts previously recovered must be refunded within the same eight-week period.

The judgment marks an important development for Assistant Professors in Tripura, particularly those who acquired higher academic qualifications while serving as teachers before their absorption into the regular Assistant Professor cadre.

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