A former SBI clerk appointed in 1978 and confirmed in February 1979 left for abroad in 1989 without informing the Bank. After returning in 2004 and seeking re-joining, the Bank rejected his request and, by letter dated 21.07.2008, declared that his services had been voluntarily abandoned with effect from 12.12.1998. The appellant then claimed pension benefits of Rs. 8,11,770/- under Section 33C(2) of the Industrial Disputes Act, 1947 before the Labour Court, which dismissed the petition for want of a pre-existing right. The Madras High Court Single Judge and, thereafter, the Division Bench in W.A. No. 1065 of 2022 both upheld that dismissal. The Supreme Court, however, chose to decide the matter on merits rather than on the technical ground of maintainability under Section 33C(2).
The Court examined the appellant's twin claims under rr. 22(i)(c) and 22(i)(a) of the SBI Employees' Pension Fund Rules, 1955. On r. 22(i)(c) — which entitles a member to pension on completing twenty years' pensionable service at his own written request irrespective of age — the Court held that pensionable service runs from the date of confirmation (17.02.1979) to the date of cessation (12.12.1998) under rr. 20 and 7, yielding only 19 years, 9 months and 25 days, falling short of the twenty-year threshold. Crucially, the Court also held that r. 22(i)(c) presupposes a voluntary retirement at the employee's request, whereas the appellant's services were declared voluntarily abandoned after prolonged unauthorised absence — a fundamentally different legal event. On r. 22(i)(a), the appellant additionally failed to satisfy the age condition of fifty years as on the date of cessation.
The Court distinguished Assistant General Manager, State Bank of India & Ors. v. Radhey Shyam Pandey [2020] 4 SCR 814 : (2020) 6 SCC 438, noting that in Radhey Shyam Pandey the employees had undisputedly retired under a recognised VRS and the controversy was confined to computation of qualifying service — entitlement itself was not in dispute. The Court similarly distinguished Rugmini Ganesh w/o Ganesh Raman Iyer v. State Bank of India, 2018 SCC OnLine Bom 3884, observing that even if the probation period were included, the appellant still failed the age condition under r. 22(i)(a). The appeal was dismissed.