The Calcutta High Court has asserted that SBI officers had no legal or enforceable right to claim reimbursement of the disputed expenses because those reimbursements were not part of the SBI Officers’ Service Rules and were only discretionary benefits granted through circulars. Since no enforceable right existed, the officers could not invoke writ jurisdiction to compel continuation of those reimbursements.
The Court further held that Rule 65A of the SBI Officers’ Service Rules expressly empowered the bank to require mandatory learning and to provide for disentitlement from reimbursements upon failure to complete such learning within the prescribed timeline. As the petitioners had not challenged Rule 65A itself, they could not successfully attack the consequences flowing from that rule merely by challenging the implementing circulars.
The Court also held that linking reimbursement with mandatory learning was neither arbitrary nor unrelated to the object sought to be achieved. In the Court’s view, the classification was justified because the object was to ensure officers remained updated and to protect the bank and its customers from operational, regulatory, money laundering, and technological fraud risks. Therefore, there was no violation of Article 14.
A Single Judge Bench of Justice Raja Basu Chowdhury rejected SBI’s objection on territorial jurisdiction and held that mere location of records outside West Bengal was not enough to oust jurisdiction when the effect of the impugned circulars was felt within the Court’s jurisdiction. On the substance of the dispute, the Bench noted that the reimbursements in question did not form part of the SBI Officers’ Service Rules and had historically been granted through circulars issued from time to time. The bank itself had stated that these reimbursements were intended to mitigate financial hardship, but they were unilateral and discretionary in nature, and not enforceable as a matter of right by the officers. The Bench also noted there was no specific denial by the petitioners to SBI’s stand that such reimbursements were outside the statutory service rules.
The Bench accepted SBI’s case that in modern banking, continuous upskilling is essential because of changing technology, regulatory expectations, anti-money laundering compliance, cyber-fraud risks, and the need to maintain secure banking systems and seamless customer service. It recorded that RBI had also issued guidance asking banks to identify specialised areas for certification, and that SBI’s Central Board had approved amendment of the service rules by introducing Rule 65A to link mandatory learning with disentitlement from reimbursements in case of non-compliance.
The Bench did not accept the Article 14 challenge. It held that officers who had updated themselves and officers who had not completed mandatory learning were not similarly situated. It also held that suspended employees could not be equated with officers on active duty. According to the Court, there was a reasonable and intelligible differentia between these categories, and the classification had a clear nexus with the objective of ensuring updated skills and reducing banking risk.
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Briefly, a petition was filed by the All India State Bank Officers’ Federation and its office-bearers challenging SBI circulars dated 30 April 2021 and 2 June 2021. These circulars introduced “mandatory learning” for officers from Scale I to V and linked completion of that learning to reimbursement of certain monthly allowances and expenses such as conveyance, newspaper/magazine, cleansing material, labour charges, and telephone/internet/mobile usage. The petitioners said that officers who did not complete the mandatory learning were denied these reimbursements, causing a reduction in their monthly pay package of about Rs.10,000 to Rs.26,000 depending on grade.
The petitioners argued that these reimbursements were meant to reduce financial hardship and had no connection with completion of training modules. They also contended that non-completion of mandatory learning already had consequences in service matters, including adverse appraisal impact and reduced promotion prospects, and therefore denial of reimbursement amounted to an additional and arbitrary penalty. They further claimed discrimination because suspended employees were allegedly still allowed such benefits even if they had not completed the mandatory learning.
SBI opposed the petition first on maintainability, saying the relevant circulars were issued from Mumbai and records were located there. On merits, SBI argued that these reimbursements were not part of the State Bank of India Officers’ Service Rules, 1992, but were discretionary benefits granted through circulars approved by the Central Human Resources Committee. SBI also relied on newly introduced Rule 65A, under which officers could be required to complete mandatory lessons within prescribed timelines, failing which they could be disentitled from claiming monthly reimbursements linked to their grade/scale.
