Supreme Court dismisses Nagaland’s govt review petition in RMSA teachers’ pay case

Morung Express News 
Dimapur | January 17

The Supreme Court of India, on January 15, has dismissed a review petition filed by the Nagaland Government seeking reconsideration of its earlier order dismissing the Special Leave Petition (SLP) against a writ appeal judgment of the Gauhati High Court concerning pay scales of Graduate Teachers appointed under the Rashtriya Madhyamik Shiksha Abhiyan (RMSA).

“We are of the considered opinion that no case for review has been set up. 5. The review petition is, therefore, dismissed,” stated the order issued by a Bench comprising Justice Dipankar Datta and Justice K. Vinod Chandran, dismissing the State’s review petition.

Background of the case

The case dates back to an advertisement issued in December 2013 for recruitment of teachers under RMSA on a contractual basis. The advertisement did not specify any scale of pay. Subsequently, by a notification dated October 28, 2015, the State Government sanctioned the creation of temporary posts of Graduate Teachers carrying a pay band of Rs 9,300–34,800 with Grade Pay of Rs 4,200.

Following selection, the teachers were appointed in 2016 on fixed monthly remuneration after signing contractual bonds. In 2018, after the merger of Sarva Shiksha Abhiyan and RMSA into Samagra Shiksha, office memoranda were issued revising the remuneration structure, leading to a reduction in pay and directions to teachers to accept the revised terms.

The affected teachers approached the Gauhati High Court, Kohima Bench.

By judgment dated May 20, 2020, a Single Judge quashed the salary-reduction orders but declined to direct grant of the sanctioned pay scale, holding that the teachers were bound by the contractual terms accepted at the time of appointment.

Aggrieved by the denial of regular pay scales, the teachers preferred a writ appeal. On March 16, 2022, a Division Bench of the Gauhati High Court allowed the appeal, holding that the teachers were appointed against sanctioned posts, possessed identical qualifications, and discharged the same duties as similarly placed teachers drawing regular pay.

The High Court directed the State to grant the sanctioned pay band with Grade Pay, applying the principle of equal pay for equal work.

Proceedings before the Supreme Court

Challenging the writ appeal judgment, the Nagaland Government filed Special Leave Petition (Civil) before the Supreme Court. On May 20, 2025, the Supreme Court dismissed the SLP, observing that it was not inclined to interfere with the High Court’s judgment.

The State subsequently filed a review petition seeking review of the Supreme Court’s order dated May 20, 2025.

By order dated January 15, 2026, the Supreme Court condoned the delay in filing the petition but rejected the application and held that no case for review had been made out. The review petition was accordingly dismissed and all pending applications, if any, were disposed of.

To recall, after nearly two weeks of continuous agitation in September, the RMSA 2016 batch of Graduate Teachers suspended their sit-in protest demanding pay scale following government assurances and the constitution of a High-Level Committee and a Sub-Committee to address the issue.

During the stir, the State government had cited the matter being sub judice as the reason for not implementing the High Court judgment.

With the subsequent of the review petition by the Supreme Court, the litigation has now reached finality. 
 



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