Patna High Court dismissed a delayed unpaid salary claim, highlighting that even valid grievances can be denied if not pursued timely, reaffirming the application of the doctrine of laches under Article 226 of the Constitution.
Thank you for reading this post, don't forget to subscribe!
BIHAR: In a recent ruling that has caught the attention of legal professionals and public servants alike, the Patna High Court in Ram Chandra Prasad vs. State of Bihar (LPA No. 135 of 2022) dismissed a claim for unpaid salary, not because the claim lacked merit, but because it came too late.
This case serves as a cautionary tale for government employees and litigants, emphasizing that even valid grievances can be denied relief if not brought to court in time. The judgment is a textbook example of how the doctrine of laches applies in Indian writ jurisprudence under Article 226 of the Constitution.
ALSO READ: Law Researchers Move Delhi HC Over Salary Hike Delay and Unpaid Arrears Since 2022
Ram Chandra Prasad, a Junior Engineer employed under the Rural Works Department, Government of Bihar, claimed he was not paid his salary for a prolonged period from 1st November 2008 to 31st January 2012. Over the years, he made representations to various concerned authorities but failed to secure any resolution.
In 2021, almost a decade after the salary issue began, he finally approached the Patna High Court by filing Civil Writ Jurisdiction Case (CWJC) No. 7874 of 2021. The case was dismissed by a Single Judge Bench on grounds of unexplained delay and laches on 11.02. 2022.
The appellant, dissatisfied filed a Letters Patent Appeal (LPA No. 135 of 2022), which was heard by a Division Bench comprising Hon’ble Acting Chief Justice Ashutosh Kumar and Hon’ble Mr. Justice Partha Sarthy.
In its judgment on 27.06.2025, the High Court held the dismissal stating that the petitioner had “slept over his cause” and failed to provide reasonable justification for inordinate delay in approaching the Court.
The Division Bench observed that though representations were made over time, mere correspondence with authorities does not stop the clock when it comes to legal rights. The Court added that the writ jurisdiction is discretionary, and such discretion cannot be exercised in favor of those who approach the Court with stale claims.
Legal Principles Involved
Doctrine of Laches
The principle of laches is a legal doctrine rooted in equity. It bars a claim when there is a unreasonable delay in asserting a legal right, causing prejudice to the opposite party. Indian Courts have consistently applied this principle in service matters, especially under Article 226, where relief is not a matter of right but subject to the discretion of the Court.
Writ Jurisdiction Under Article 226
Article 226 empowers High Courts to issue writs for enforcement of fundamental and legal rights. However, the Court exercises this power only when the petitioner demonstrates due diligence and urgency. if there is unexplained delay, the High Court may decline to interfere, even in the case with substantive legal merit.
This case has broader implications for thousands of public servants across India. It sends a clear and strong message:
- Timely action is crucial
- Administrative remedies are not a substitute for judicial remedies
- Merit alone do not guarantee relief
The dismissal of the appeal in this case, is a legal lesson. Justice is not just about being right, it is about acting at the right time. The case reaffirms the judiciary’s position that justice delayed in seeking can be justice denied, especially when the legal remedies are discretionary and time sensitive.
CASE TITLE: RAM CHANDRA PRASAD VERSUS THE STATE OF BIHAR
READ JUDGMENT HERE
Click Here to Read Previous Reports on Salary
FOLLOW US ON YOUTUBE FOR MORE LEGAL UPDATES
