WP(MD)/14747/2026 of R.Sarojini Vs The Director of Elementary E on 7 October 2026

ORDER

The petitioner is working as a Secondary Grade Teacher in the fourth respondent School. She was granted an incentive increment for possessing a B.A. degree in Economics. However, the same has been cancelled by the order impugned in this Writ Petition, in the light of the order passed by this Court in W.P.(MD) No.22704 of 2016, dated 20.01.2025. Contending that the order passed by this Court in W.P.(MD) No.22704 of 2016, dated 20.01.2025, has subsequently been set aside by a Division Bench in W.A.(MD) No.874 of 2025, dated 09.01.2026, the petitioner has filed the present Writ Petition.

2. This Court, while entertaining the Writ Petition, has granted an order of interim stay on 04.06.2026. While so, the official respondents have filed a counter affidavit along with an application to vacate the interim order and, therefore, with the consent of the learned counsel appearing on either side, this Writ Petition is taken up for final disposal.

3. The learned Special Government Pleader appearing for respondents 1 to 3 submits that the petitioner is taking classes only up to the V Standard and that her qualification in B.A. Economics has no relevance to the subjects dealt with by her. Therefore, in view of the ratio laid down by this Court in W.P.(MD) No.22704 of 2016, dated 20.01.2025, the order granting incentive increment in favour of the petitioner was cancelled. He has also relied upon a subsequent order of this Court in W.P.(MD) No.24663 of 2025, dated 03.07.2026, and submits that this Court, after referring to three other judgments of the Division Bench, held that a M.A. degree in Economics, which is not relevant to the subjects taught up to the V Standard, cannot be considered for the grant of an incentive increment.

4. The learned counsel for the petitioner submits that the order impugned in the present Writ Petition was passed based on the earlier order of this Court in W.P. (MD) No.22704 of 2016, dated 20.01.2025, and when the said order itself has been set aside by the Division Bench, the order impugned in the present Writ Petition would not survive.

5. This Court has considered the rival submissions made on either side and perused the materials placed on record.

6. The issue involved in the present case is the entitlement of the petitioner to an incentive increment for possessing a B.A. degree in Economics. Admittedly, the petitioner is working as a Secondary Grade Teacher and is expected to take classes up to the V Standard. There is no subject relating to Economics prescribed for the students up to the V Standard. Therefore, the qualification possessed by the petitioner in B.A. Economics has no relevance to the subjects taught by her.

7. As rightly pointed out by the learned Special Government Pleader, this Court, following three judgments of the Division Bench, has rendered a reasoned judgment in W.P.(MD) No.24663 of 2025, dated 03.07.2026. The relevant portion of the said order reads as under: “Black's Law Dictionary (2nd Edition) defines "incentive compensation" as "payments in excess of agreed wages; a bonus and profit sharing as an incentive for good performance." Though the definition arises in the context of employment law, it reinforces the principle that an incentive is linked to the benefit expected by the employer and not merely to the possession of an additional qualification. In the case of teachers, the knowledge and skills acquired through the higher qualification must have a direct bearing on the teaching duties discharged by them and should ultimately enure to the benefit of the students. Mere acquisition of an additional qualification, without any corresponding educational benefit to the students or the institution, cannot, by itself, confer a right to claim an incentive increment.

13. Applying the above principles to the facts of the present case, this Court finds that the petitioner is serving as a Secondary Grade Teacher teaching students at the elementary and middle school level. Though Economics is one of the subjects in the Higher Secondary syllabus, that by itself does not entitle the petitioner to claim incentive increment. The qualification of M.A. (Economics) has no direct or reasonable nexus with the duties ordinarily discharged by the petitioner as a Secondary Grade Teacher. The petitioner has not established that the additional knowledge acquired by him through the said qualification would benefit the students taught by him or fulfil the object for which the scheme of incentive increments was introduced. Therefore, this Court holds that the petitioner is not entitled to incentive increment for acquiring the M.A. (Economics) qualification under GO.Ms.No.324, Education, Science and Technology Department (E2), dated 25.04.1995.

14. The above conclusion also stands fortified by the decisions of this Court. A Division Bench of this Court in S.Thangathai v. Director of School Education [W.A.(MD)No.918 of 2015 dated 17.12.2015] explained the object of granting incentive increments to teachers in the following words: "6. It is quite unfortunate that the object of grant of advance incentive increment to Teachers, is many times lost sight of. The object is to encourage Teachers to pursue higher education, so that the higher education that they pursue enures to the benefit of the students. In this case, the appellant is a Physical Education Teacher. We do not know how the acquisition of a Under Graduate Degree in History and Post Graduate Degree in History would have enured to the benefit of the students, especially from a Physical Education Teacher." The Division Bench thus emphasised that the object of the scheme is not merely to reward acquisition of higher qualifications, but to ensure that the higher qualification acquired by the teacher ultimately enures to the benefit of the students.

15. Similarly, another Division Bench of this Court in R.Sakthivel v. The Secretary to Government, Education Department and Others [W.A.(MD)No.910 of 2022 dated 24.08.2022] held that the object of granting incentive increments is to encourage teachers to acquire qualifications that would be beneficial to the students. The relevant observations read as follows:

"13. The appellant submitted that the object of granting incentive increment is to lift the morale of the teachers. But the Government states that the object of granting incentive increment is to encourage the Teachers to qualify themselves, so that their qualification would be beneficial to the students. In the present case the petitioner was working as Secondary Grade Teacher taking class for students from 1 to 5 standards and the qualification of M.Sc. Physics would not be beneficial to the students studying in the standards 1 to 5. Therefore, the Government is right in denying the incentive increment for higher qualifications when the higher qualification is not beneficial for the students studying in the standards 1 to 5." The principle laid down by the Division Bench squarely applies to the facts of the present case.

16. This Court has also taken a similar view in Arul Rani v. State of Tamil Nadu [W.P.(MD)No.15098 of 2020 dated 16.03.2023], wherein recovery of the incentive increment granted to a Secondary Grade Teacher for acquiring M.A. and M.Phil. qualifications was upheld. This Court observed as follows: "15. ... An incentive must be a reward to encourage a worker, who is performing better than the others. It must be depending upon the performance and not on possession of any degree alone." The above observation succinctly brings out the true nature of an incentive increment and fully supports the view taken by this Court in the present case.”

8. In addition to the above, a Division Bench, in W.A.(MD) No.444 of 2020, dated 24.07.2025, has also taken a similar view. In view of the aforesaid judgments and the facts of the present case, this Court is not inclined to entertain this Writ Petition. Accordingly, the Writ Petition is dismissed. No costs. Consequently, connected Miscellaneous Petitions are closed. 07-10-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No mbi To

1. The Director of Elementary Education College Road, Chennai - 600006

2. The District Education Officer, Tenkasi

3. The Block Educational Officer-2 Melaneelithanallur, Tenkasi District

B.PUGALENDHI, J. mbi WP(MD) No. 14747 of 2026 AND WMP(MD) Nos. 11092 & 16220 of 2026 07-10-2026