Supreme Court Landmark: Ad Hoc Employees Without Interviews Cannot Be Regularised
In a significant ruling that reinforces the sanctity of public recruitment processes, the Supreme Court of India has partially set aside a judgment of the Punjab and Haryana High Court on the regularisation of contractual and ad hoc employees.
The decision, delivered by a bench of Justices PS Narasimha and Atul Chandurkar, clarifies the thin line between “irregular” and “illegal” appointments, emphasising that transparency—specifically through public advertisements and interviews—is non-negotiable for permanent government employment.
The Core of the Dispute
The case centred on four notifications issued by the Haryana government in 2014 intended to regularise Group B, C, and D employees. While the High Court had previously quashed all of them, the Supreme Court took a nuanced approach:
The June 2014 Notifications (UPHELD): The Court restored these, noting they were meant for employees who met recruitment norms (sanctioned posts, qualifications, and reservation) but were left out of previous policies.
The July 2014 Notifications (STRUCK DOWN): These were declared illegal because they sought to regularise staff hired without public advertisement or interview.
Why the “July Notifications” Failed the Legal Test
The Court’s reasoning was anchored in the landmark judgment of the Secretary, State of Karnataka v. Umadevi (2006). The Justices highlighted several red flags:
Lack of Transparency: Hiring without advertisements creates “doubts as regards the manner of engagement.”
Future Cut-off Dates: The policy attempted to include employees who would only complete 10 years of service by 2018, four years after the notification was issued.
Blocking Regular Recruitment: By reserving posts for these ad hoc employees, the state was effectively preventing qualified candidates from applying through a fair, competitive process.
A “Humanitarian” Middle Ground
While the Court struck down the July notifications, it didn’t leave the affected employees completely stranded. Invoking Article 142, the Court directed that:
Employees already in service under the 2014 policies should not be removed.
Instead of regularisation, they will be placed on the lowest pay scale for their respective posts, in accordance with the principle of “equal pay for equal work.”
Key Takeaways for Public Service
This judgment serves as a stern reminder to State Governments that executive power under Article 162 cannot be used to bypass the constitutional requirement of merit-based public appointments. Regularisation is a “one-time measure,” not a backdoor for permanent employment.
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Presented by
Advocate Vijay Singh
MS LLB LLM MBA
Ex MO, Ex VP, Law Counsel