Calcutta HC Dismisses SBI Officers’ Union Writ Challenging Mandatory Learning Linkage to Allowance Reimbursements
The High Court at Calcutta held that SBI officers have no enforceable right to expense reimbursements, and withholding those reimbursements from officers who skip mandatory learning is not arbitrary.
The High Court at Calcutta, in a judgment dated 18 June 2026, dismissed a writ petition filed by the All India State Bank Officers’ Federation challenging two State Bank of India circulars that made expense reimbursements conditional on the completion of mandatory learning courses. Justice Raja Basu Chowdhury, sitting singly on the original side, held that the reimbursements in question do not form part of the SBI Officers’ Service Rules, 1992, and officers accordingly have no legal right to enforce them. The court also held that the classification between officers who complete mandatory learning and those who do not rests on a reasonable and intelligible differentia, and does not offend Article 14 of the Constitution of India.
The Dispute Before the Court
The petitioner no.1, the All India State Bank Officers’ Federation, is a registered trade union. The petitioner nos. 2 and 3 were its General Secretary and a member respectively, though both had superannuated by the time the matter came to be decided. The writ petition challenged two circulars issued by State Bank of India — one dated 30 April 2021 and another dated 2 June 2021 — both falling under the heading “Mandatory Learning” for top executive officers from Scale I to Scale V.
Since at least 1979–80, SBI had been reimbursing its officers for a range of expenses: conveyance, newspapers and magazines, cleansing materials, labour charges, and residential telephone, internet, broadband and mobile connection charges. The extent of those reimbursements had been revised through various circulars over the decades. The financial impact was not trivial — the petitioners placed the monthly impact on individual officers at between approximately Rs. 10,000 and Rs. 26,000, depending on scale.
The 30 April 2021 circular linked eligibility for those reimbursements to the completion of a mandatory learning course. Officers from Scale I to V who had not completed the course were rendered disentitled to reimbursement. The 2 June 2021 circular introduced what the parties referred to as a “5 in 1 disincentive,” applying a set of penalties to officers who failed to complete mandatory learning within prescribed timelines. The federation challenged both instruments as arbitrary and violative of Article 14.
The Legal Issue
The core question Justice Basu Chowdhury identified was whether officers could claim the reimbursement of these expenses as an enforceable right, and whether the condition of mandatory learning had any rational nexus to the object of disbursing those allowances.
A preliminary objection on maintainability was also raised. SBI argued that since the second respondent is located in Mumbai and the circulars were issued from the Strategic Training Unit there, the Calcutta High Court lacked jurisdiction. The court rejected that argument. It held that the mere presence of records outside the jurisdiction is not sufficient to exclude the court’s jurisdiction, particularly when the effect of the circulars is felt within its territorial limits.
Mr. Soumya Majumder, Senior Advocate for the federation, advanced several arguments. He submitted that the object of the reimbursements was to mitigate the financial hardship of officers, and that linking those reimbursements to mandatory learning had no nexus to that object. He pointed to an internal memorandum dated 1 February 2022, which revealed that a suspended employee who had not completed mandatory learning was nevertheless permitted to claim the same reimbursements — while an officer on active duty who had not completed the course was denied them. Mr. Majumder argued this created an irrational and arbitrary classification, and amounted to double jeopardy, since non-completion already attracted adverse marking in an officer’s Annual Confidential Report and affected promotion prospects.
Mr. Subrata Kumar Sinha, Advocate for SBI, countered at the threshold that these reimbursements are not covered under the State Bank of India Officers’ Service Rules, 1992 (SBIOSR). They were introduced unilaterally by the bank and approved by its Central Human Resources Committee (CHRC). The bank could unilaterally withdraw them at any time, and officers could not claim them as a matter of right. He further drew the court’s attention to Rule 65A, introduced into the SBIOSR by the bank’s Central Board at its meeting of 24 March 2021, which explicitly authorised the CHRC to disentitle officers who fail to complete mandatory lessons from claiming monthly reimbursements.
How the Bench Reasoned
Justice Basu Chowdhury accepted SBI’s position on the foundational question. The court found, as a matter of undisputed fact on the pleadings, that the reimbursements do not form part of the SBIOSR. SBI’s own affidavit had stated as much: the bank reimburses these costs to mitigate financial hardship, based on circulars approved by the CHRC, but the officers have no right to seek enforcement.
The court then addressed the argument that Rule 65A itself had not been challenged. The petitioners had confined their challenge to the two implementing circulars, while Rule 65A — which is the source of the power to disentitle — was left intact. Justice Basu Chowdhury held that unless the rule itself is challenged, the consequences flowing from that rule cannot be impeached. Since Rule 65A empowered the bank to issue the impugned circulars, the circulars could not be struck down independently.
On the Article 14 challenge, the court rejected the argument that officers who had not completed mandatory learning were similarly situated to those who had. There is, in the court’s view, a reasonable and intelligible differentia between officers who have updated their skills and those who have not. The classification serves a legitimate object: ensuring that officers have the required knowledge to protect the bank and its customers from money laundering and cyber fraud. The court noted that SBI staff observe Anti Money Laundering and Countering Financial Terrorism (AML/CFT) Day on 2 November each year, and Risk Awareness Day on 1 September, both involving formal pledges to continuously update knowledge — reflecting an institutional commitment to ongoing learning that, in the court’s view, the mandatory learning framework implements.
The suspended-officer comparison fared no better. Justice Basu Chowdhury held that officers on active duty and officers under suspension are simply not comparable categories. The two cannot be equated, and the different treatment of each does not produce an impermissible classification.
The court addressed the double jeopardy argument directly. The petitioners had said that since non-completion already attracts adverse ACR markings affecting promotion, withdrawal of reimbursements is an additional penalty for the same default. The court rejected this framing: there is no legal right to the reimbursements in the first place, so their withdrawal is not a penalty at all. Without a pre-existing right, there can be no question of jeopardy.
Both precedents cited by the petitioners were distinguished. B. Manmad Reddy and Ors. v. Chandra Prakash Reddy and Ors., reported in (2010) 3 SCC 314, involved classification between promotee and direct recruit employees who had been integrated into a single cadre but were still being treated differently. The court found that case has no application where the distinction is between officers who have and have not complied with a reasonable institutional requirement. Virendra Krishna Mishra v. Union of India & Ors., reported in (2015) 2 SCC 712, concerned encadrement of three posts without considering other similarly placed posts covered by the same recruitment rules — again, a different fact situation.
The court observed that in a fast-changing banking environment, where technological fraud and money laundering pose constant threats, the least that could be expected of a bank officer is to keep their skills current. The mandatory learning framework had been developed partly in response to a Reserve Bank of India circular dated 11 August 2016, which directed banks to make certificate courses mandatory for officials working in credit, risk, forex, treasury and accounts. The RBI had also flagged non-completion of certifications during its annual Risk Assessment Reports of SBI.
Justice Basu Chowdhury observed that the petitioners were, in effect,
On the 5 in 1 Disincentive
The 2 June 2021 circular introduced the “5 in 1 disincentive” as an additional measure. SBI clarified in an affidavit affirmed on 22 November 2022 that this disincentive had not been applied to officers in the top executive grade, consistent with the position in the previous financial year. The mandatory learning instructions for top executives are generalised in nature and are not role-based certifications, unlike those applicable to Scale I to V officers. The court recorded this clarification but did not separately address the 5 in 1 disincentive given its overall dismissal of the petition.
Outcome
Justice Raja Basu Chowdhury dismissed WPO 1278 of 2022 along with the connected GA 1 of 2022. The challenge to the circulars dated 30 April 2021 and 2 June 2021 failed on all grounds. The court directed that urgent photostat certified copies of the order be made available to parties on a priority basis upon compliance of the required formalities.