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Supreme Court Upholds Limited Regularisation but Strikes Down Blanket Future Policy for Ad Hoc Employees

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The Supreme Court of India has delivered a nuanced judgment on the contentious issue of regularisation of contractual, ad hoc, and daily wage employees in Haryana, partly upholding and partly striking down the State’s policies. 

The bench of Justice Pamidighantam Sri Narasimha and Justice Atul S. Chandurkar allowed regularisation of employees appointed without any transparent process would undermine the rule of law and deprive eligible candidates of fair competition. It also questioned the rationale behind fixing a future cut-off date, noting that it would prevent regular recruitment for several years and distort the public employment framework. 

At the heart of the dispute were four notifications dated June 16, June 18, and July 7, 2014, issued by the Haryana government to regularise services of Group B, C, and D employees working on non-permanent basis. These policies had earlier been quashed by the Punjab and Haryana High Court, prompting appeals before the Supreme Court. 

The Supreme Court drew a clear distinction between the June 2014 notifications and those issued on July 7, 2014. It upheld the validity of the June 16 and June 18 notifications, observing that these were aimed at extending the benefit of regularisation to employees who had been left out of earlier policies, particularly the 1996 regularisation framework. The Court noted that these policies required employees to meet strict eligibility conditions, including possession of prescribed qualifications and engagement against sanctioned posts, thereby aligning with constitutional requirements. 

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Importantly, the Court emphasized that such a measure was consistent with the principles laid down in the landmark judgment of Secretary, State of Karnataka vs Umadevi, which permits regularisation as a one-time exercise for eligible employees who have served long periods under irregular (but not illegal) appointments. The Court held that the State’s attempt to extend similar benefits to remaining eligible employees could not be termed arbitrary or illegal. 

However, the Court took a firm stance against the July 7, 2014 notifications. These policies sought to regularise employees who would complete ten years of service in the future (by December 31, 2018), including those who were not appointed through any formal recruitment process such as advertisement or interview. The Court found this approach fundamentally flawed, holding that such regularisation would effectively legitimise backdoor entries into public service, violating constitutional guarantees of equality and fair opportunity in public employment. 

Despite declaring the July 7 notifications as arbitrary and illegal, the Court exercised its powers under Article 142 of the Constitution to grant limited relief to affected employees. Recognising that many such employees had continued in service for years and had settled in life, the Court directed that they should not be removed from service. Instead, they would be retained at the lowest pay scale applicable to their posts, balancing equity with legality. 

The judgment thus strikes a balance between protecting long-serving employees and upholding constitutional principles governing public employment. While it safeguards legitimate cases of regularisation, it sends a strong message against indiscriminate or politically motivated regularisation policies that bypass due process.

Case Details

Case Title: Madan Singh And Others Versus  State Of Haryana

Citation: JURISHOUR-838-SC-2026

Case No.: CIVIL APPEAL NO.1996 OF 2024

Date:  16/04/2026

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Amit Sharma
Amit Sharma
Amit Sharma is the Content Editor at JurisHour. He has been writing about the Indian legal market. He has covered tax & company litigation stories from the Supreme Court, High Courts and Various Tribunals. Amit graduated from MLSU Law College with B.A.LL.B. and also holds an LL.M. from MLSU, Udaipur, Rajasthan. An Advocate in Taxation, and practised in Tribunals as well as Rajasthan High Court and pursued Masters in Constitutional Law. He started out small with little resources but a big plan to take tax legal education to the remotest locations across India and eventually to the world. His vision is to make tax related legal developments accessible to the masses.

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