The Supreme Court clarified that the principle of “equal pay for equal work” cannot be applied mechanically merely because employees perform similar functions. In G.P. Sangeetha & Ors. v. State of Kerala & Ors., the dispute concerned different groups of Higher Secondary School Teachers appointed through direct recruitment and through transfer or promotion. The direct recruits claimed parity with teachers receiving a higher pay scale, arguing that their qualifications, duties and responsibilities were substantially similar. The Supreme Court held that functional similarity alone is insufficient to establish complete equality for the purpose of pay fixation. Factors including educational qualifications, experience, source of recruitment, mode of appointment, responsibilities and accountability may justify a reasonable classification between employees. The Court observed that previous service experience can constitute a legitimate basis for differential pay where the classification has a rational connection with the object of the pay structure. The judgment examined Articles 14 and 39(d) of the Constitution and emphasised that courts should not interfere with a reasonable administrative classification merely because employees perform comparable functions. The appeals were accordingly dismissed.