No Pension Without 20 Years’ Service or Voluntary Retirement; Abandonment of Service Not Equivalent: Supreme Court

Case Name: K.G. Seshadri v. The Trustees of State Bank of India & Anr.

Citation: 2026 INSC 333

Date of Judgment/Order: 08 April 2026

Bench: Justice Prashant Kumar Mishra and Justice N.V. Anjaria

Held: The Supreme Court held that pension entitlement under the State Bank of India Employees’ Pension Fund Rules, 1955 requires strict fulfillment of eligibility conditions, including completion of 20 years of qualifying service and satisfaction of conditions under the relevant rule. The Court further held that voluntary abandonment of service cannot be equated with voluntary retirement, and an employee who neither completes the requisite qualifying service nor meets the prescribed age criteria is not entitled to pension.

Summary: The appellant, a bank employee, claimed pensionary benefits on the ground that he had completed more than 20 years of service and was deemed to have voluntarily retired. His claim was rejected by the Bank, leading to multiple rounds of litigation before the Labour Court and the High Court, both of which dismissed his claim primarily on maintainability under Section 33C(2) of the Industrial Disputes Act. Before the Supreme Court, the appellant relied on Rule 22(i)(c) of the Pension Fund Rules, contending that completion of 20 years’ service irrespective of age entitled him to pension. The Court examined the scheme of the Pension Rules, including Rules 7 and 20, and held that pensionable service must be calculated from the date of confirmation, not initial appointment. On this basis, the appellant fell short of 20 years of qualifying service. The Court further found that the appellant had remained unauthorizedly absent and was deemed to have voluntarily abandoned service, not voluntarily retired. It distinguished precedents relied upon by the appellant, holding that those cases involved admitted entitlement to pension or valid voluntary retirement schemes, which were absent in the present case. The Court also considered Rule 22(i)(a) and held that the appellant failed to meet both the service and age requirements under that provision as well.

Decision: The appeal was dismissed, the findings of the High Court were upheld, and the appellant was held not entitled to any pensionary benefits. All pending applications were disposed of.