Pay scale parity depends on duties and service relativity, not gazetted status or education alone.

Fixation of pay scales and equation of posts are primarily executive functions, and writ interference is justified only where the pay structure is demonstrably arbitrary or irrational. Gazetted status, inclusion in State Service, or higher educational qualifications do not by themselves require parity with higher services when duties, responsibilities, recruitment level, promotion avenues, and service relativities differ. On that reasoning, Sub-Registrars were not entitled to be placed in the same higher scale as Munsiffs or Judicial Officers, because their functions were materially different. The State's pay fixation was restored, while the Government was directed to reconsider the appropriate scale for Sub-Registrars by a speaking order after hearing the employee association.

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Issues: Whether the High Court was justified in directing placement of Sub-Registrars in the higher pay scale on the basis of gazetted status, inclusion in State Service, educational qualification, and alleged discrimination under Articles 14 and 16 of the Constitution; and whether the fixation of pay scales by the State and the Pay Commission could be interfered with in writ jurisdiction.

Analysis: Fixation of pay scales and equation of posts are primarily matters for the executive and expert pay-revision bodies. Judicial interference is warranted only where there is clear arbitrariness or a grave error resulting in injustice. The mere fact that the Sub-Registrars were given gazetted status and treated as part of the State Service did not by itself require placement in the same scale as higher State services. Pay structure must reflect the nature of duties, responsibilities, recruitment level, promotion avenues, and service relativities. The Court found that the duties of Sub-Registrars were materially different from those of Munsiffs and Judicial Officers and that the High Court had erred in treating them as equals for pay purposes. Although the educational qualification for direct recruitment had been raised, that factor alone could not override the differences in duties and responsibilities or compel judicially imposed parity with another service.

Conclusion: The High Court's direction granting the higher pay scale was unsustainable. The State Government's pay fixation was restored, though the Government was directed to re-examine the appropriate scale for Sub-Registrars by a speaking order after hearing the employee association.

Final Conclusion: The appeals succeeded and the impugned judgment and orders were set aside, with a direction for reconsideration of the pay scale question by the State Government.

Ratio Decidendi: Courts should not ordinarily revise pay scales or equate posts in writ jurisdiction unless the pay fixation is demonstrably arbitrary or irrational, and equality cannot be used to equate posts with materially different duties and responsibilities.

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