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Supreme Court of India 2021-12-16 allowed

THE SECRETARY TO GOVT. DEPARTMENT OF EDUCATION (PRIMARY) & ORS vs BHEEMESH ALIAS BHEEMAPPA

Bench: 2 — Hemant Gupta, V. Ramasubramanian

In Brief

A Government servant's unmarried sister died in 2010 as an Assistant Teacher. The respondent claimed compassionate appointment benefits on her behalf. In 2012, the rules were amended to extend compassionate appointment to unmarried dependent brothers of unmarried female employees. The Tribunal and High Court held the amendment applied retrospectively. The Supreme Court reversed this, holding that rule amendments enlarging benefits do not apply retrospectively to deaths occurring before the amendment. The Court reasoned that statutory interpretation must be based on fixed factors (date of death) rather than variable ones (date of consideration). Retrospective effect applies only to amendments made to cure constitutional defects, not policy-driven expansions of benefits.

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Administrative Law Compassionate Appointment Constitutional Law Civil Service Law Statutory Interpretation Retrospective Application of Rules Articles 14 and 16

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