Pension under SBI Rules Requires Strict Fulfilment of Qualifying Service and Retirement Conditions

 Pension under SBI Rules Requires Strict Fulfilment of Qualifying Service and Retirement Conditions

Facts

The Appellant, a clerk in SBI, ceased working after prolonged absence and was treated by the Bank as having voluntarily abandoned service (12.12.1998). In 2008, the Bank declared him voluntarily retired.

The Appellant sought pension by filing a claim under s. 33C(2) ID Act, which was dismissed for lack of jurisdiction (no pre-existing right). Subsequent writ proceedings also failed. The Appellant contended he had completed over 20 years of service and was entitled to pension under Rule 22(i)(c) of the SBI Pension Fund Rules, 1955.

Issues Framed

Whether the Appellant was entitled to pension under the SBI Pension Fund Rules, particularly under Rule 22(i)(c) or Rule 22(i)(a).

Court’s Reasoning

(a) Nature of Proceedings under s. 33C(2) ID Act
The Court observed that such proceedings are “in the nature of execution proceedings” and require a pre-existing right, which was absent as entitlement to pension itself was disputed (Para 17).

(b) Interpretation of Pension Rules
Under Rule 22(i)(c), two conditions must be satisfied:
(i) completion of 20 years’ pensionable service; and
(ii) retirement at the employee’s request.

The Court held that pensionable service must be computed from confirmation (Rule 7 read with Rule 20). On this basis, the Appellant’s service was 19 years, 9 months, 25 days, i.e., less than 20 years (Para 24).

(c) Voluntary Retirement vs Abandonment
The Court held that the case was not one of voluntary retirement but of “voluntary abandonment of the services” due to unauthorized absence (Paras 25–26). Hence, Rule 22(i)(c) was inapplicable.

(d) Inapplicability of Precedents
The Court distinguished Radhey Shyam Pandey as involving undisputed entitlement under VRS, whereas here “the very foundation… is seriously disputed” (Para 28).

(e) Rule 22(i)(a) Analysis
Under Rule 22(i)(a), the employee must:
(i) complete 20 years of service; and
(ii) attain 50 years of age.

The Appellant satisfied neither condition—he lacked qualifying service and had not attained the required age (Para 30).

Held

The Appellant was not entitled to pension under either Rule 22(i)(c) or Rule 22(i)(a). The appeal was dismissed.

Ratio

Pension under SBI Pension Fund Rules accrues only upon strict fulfilment of qualifying service and retirement conditions; voluntary abandonment of service and failure to meet minimum service or age thresholds disentitle the employee from pension.

Case Details

Citation: 2026 INSC 333
Decided on: 08 April 2026
Case Title: K.G. Seshadri v. Trustees of State Bank of India & Anr.
Court: Supreme Court of India
Bench: Prashant Kumar Mishra J., N.V. Anjaria J.


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