Case Note & Summary
The Supreme Court heard an appeal by the State challenging a High Court judgment that allowed a writ petition filed by Ayurveda post-graduate students seeking stipend parity with Allopathy post-graduate students. The students contended discrimination as they performed similar duties, but the State argued the duties were not comparable. The Court considered the precedent in State of Gujarat v. Dr. P.A. Bhatt, where it was held that Ayurveda and Allopathy doctors do not perform equal work, thus not entitled to equal pay. In that case, a comparative chart highlighted differences such as emergency duties, surgery, and nature of treatment, which the High Court had overlooked. The Supreme Court analyzed these differences, noting that Allopathy doctors handle emergencies and trauma care, which Ayurveda doctors cannot perform due to the nature of their science. It concluded that the duties are not equal, making the High Court's order unsustainable. The appeal was allowed, quashing the High Court judgment and dismissing the writ petition, with the Court emphasizing that while promoting indigenous medicine, equal pay requires equal work, which was not established here.
Headnote
A) Constitutional Law - Equality and Non-Discrimination - Article 14 of the Constitution of India - Equal Pay for Equal Work - Dispute pertained to stipend discrimination between Ayurveda and Allopathy post-graduate students - Court held that duties discharged by Ayurveda students are not comparable to Allopathy students, thus no violation of equality - Held that classification based on nature of duties is reasonable and not discriminatory (Paras 2-12). B) Administrative Law - Judicial Review - Mandamus and Stipend Parity - Writ Petition No. 6415 of 2015 - High Court had directed state to treat Ayurveda students at par with Allopathy students in stipend - Supreme Court quashed the High Court order, finding it unsustainable due to differing duties - Appeal allowed, writ petition dismissed (Paras 2-14).
Issue of Consideration
Whether Post-Graduate students in Ayurveda stream are entitled to stipend at par with Post-Graduate students in Allopathy stream under the principle of equal pay for equal work
Final Decision
Appeal allowed, impugned judgment and order quashed and set aside, Writ Petition No. 6415 of 2015 dismissed
Law Points
- Equal pay for equal work principle
- discrimination in stipend based on nature of duties
- classification of medical streams
- judicial review of administrative decisions
