Equal pay for equal work cannot erase statutory classification among tribunal office-holders when duties and retirement conditions differ.

The statutory framework of the Administrative Tribunals Act, 1985 treated the Chairman, Vice-Chairmen and Members as distinct classes for appointment, tenure, pay and superannuation, and the different service conditions reflected that rational classification. Because the Act assigned administrative functions to Vice-Chairmen that were not entrusted to Members, the foundational identity of status and duties required for equal pay for equal work was not established. The constitutional role of tribunals in service matters did not make all office-holders equivalent to High Court Judges for every purpose. The claim for parity in pay and retirement age was rejected, and the Article 14 challenge failed.

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Issues: Whether the Members of the Central Administrative Tribunal were entitled to the same pay and age of superannuation as the Vice-Chairmen on the basis of equal pay for equal work and Article 14 of the Constitution.

Analysis: The statutory scheme of the Administrative Tribunals Act, 1985 treated the Chairman, Vice-Chairmen and Members as distinct categories for appointment, tenure, pay and superannuation. The Act itself fixed different ages of retirement and different service conditions, while also assigning administrative functions to the Vice-Chairman that were not entrusted to Members. The constitutional provisions enabling administrative tribunals contemplated a separate legislative framework for their constitution, powers and service conditions. The fact that the Tribunal exercised jurisdiction in place of the High Court for service matters did not make every office-holder in the Tribunal equivalent to a High Court Judge for all purposes. The principle of equal pay for equal work could not override the express statutory classification where the foundational premise of identity of status and functions was not established.

Conclusion: The claim of parity in pay and superannuation for Members of the Tribunal was rejected and the challenge under Article 14 failed.

Ratio Decidendi: Where the parent statute itself creates distinct classes of Tribunal office-holders and prescribes different service conditions on a rational statutory scheme, equal pay for equal work cannot be invoked to erase that classification or to compel parity in pay or retirement age.

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