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Issues: (i) Whether Section 11(2) of the Karnataka State Civil Services (Regulation of Promotion, Pay and Pension) Act, 1973 was unconstitutional for attempting to nullify and overrule a final judicial direction binding on the State. (ii) Whether the limiting words in Section 4(2), 4(3) and 4(8) of the Karnataka State Civil Services (Regulation of Promotion, Pay and Pension) Act, 1973 could operate to deny consequential monetary benefits flowing from deemed promotions granted under a final court order.
Issue (i): Whether Section 11(2) of the Karnataka State Civil Services (Regulation of Promotion, Pay and Pension) Act, 1973 was unconstitutional for attempting to nullify and overrule a final judicial direction binding on the State.
Analysis: The Court held that a legislature may alter the law generally and retrospectively affect a class of persons, but it cannot set aside an individual judgment inter partes and re-open rights finally determined between the parties. Section 11(2), by requiring earlier judgments, decrees and orders concerning promotion and consequential pay to be reviewed and re-determined under the Act, was aimed at bypassing a final mandamus already binding on the State. That amounted to an encroachment upon the judicial field and an exercise of judicial power under the guise of legislation.
Conclusion: Section 11(2) was struck down as ultra vires, unconstitutional, illegal and void.
Issue (ii): Whether the limiting words in Section 4(2), 4(3) and 4(8) of the Karnataka State Civil Services (Regulation of Promotion, Pay and Pension) Act, 1973 could operate to deny consequential monetary benefits flowing from deemed promotions granted under a final court order.
Analysis: The Court read the earlier final High Court direction as expressly granting deemed promotions together with all consequential benefits, including financial benefits. Since the State had accepted the binding effect of that direction and had not challenged it further, the impugned provisions could not be used to cut down arrears and salary benefits arising from those deemed promotions. The statutory clauses denying arrears were therefore inconsistent with the final judicial command and had to yield to it to that extent.
Conclusion: The impugned words in Section 4(2), 4(3) and 4(8) were read down so that they would not apply where contrary directions of competent courts against the State had already become final.
Final Conclusion: The petition succeeded, the State was required to honour the final High Court mandate, and the petitioners were held entitled to the consequential financial benefits flowing from their deemed promotions.
Ratio Decidendi: A legislature cannot, by a special enactment, nullify a final judgment inter partes or deny relief expressly granted by a binding judicial order; if a statutory provision conflicts with such a final mandate, it must yield or be read down to preserve the court-directed rights.