Promissory estoppel in public employment binds a statutory authority to regularise trainees, with seniority protected accordingly.

A statutory public authority that repeatedly represented to trainee engineers that they would be absorbed in regular service was bound by promissory estoppel and could not defeat regularisation by relying on its own service rules after the engineers altered their position and served the authority. Regular appointment was therefore directed. On seniority, the appellants were entitled to appointment in the appropriate cadre, with protection against being placed above earlier permanent or temporary recruits, while remaining senior to recruits appointed during the pendency of the appeals. The Court also adjusted relief to avoid prejudice to persons not before it.

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Issues: (i) whether the Board was bound by its representations and resolutions to regularise the trainee engineers despite the service rules framed under the Electricity (Supply) Act, 1948; (ii) whether the appellants were entitled to be appointed in the appropriate cadre with consequential seniority protection.

Issue (i): whether the Board was bound by its representations and resolutions to regularise the trainee engineers despite the service rules framed under the Electricity (Supply) Act, 1948.

Analysis: The Board was a statutory authority and State within Article 12 of the Constitution of India. It had repeatedly held out to the trainee engineers that they would be absorbed in regular service, had called upon them to continue in service, and had later resolved to appoint them on a provisional regular basis without further examination. The Court applied the doctrine of promissory estoppel and held that a public body cannot avoid a promise on the basis of its own rules where the promisee has altered his position to his prejudice, particularly when the authority had derived advantage from the services of the appellants.

Conclusion: The Board was bound to regularise the appellants' appointments.

Issue (ii): whether the appellants were entitled to be appointed in the appropriate cadre with consequential seniority protection.

Analysis: While directing regular appointment, the Court protected the rights of existing permanent and temporary recruits already in service prior to 1983 and held that the appellants could not claim seniority above them. At the same time, appointments made pendente lite were subject to the result of the appeals, and the appellants, being in service earlier than the later recruits, were entitled to rank above such subsequent recruits. The relief was shaped to avoid prejudice to persons not before the Court while enforcing the Board's obligation to absorb the appellants.

Conclusion: The appellants were entitled to regular appointment in the appropriate cadre and to seniority above recruits made during the pendency of the appeals, but not above earlier permanent or temporary recruits.

Final Conclusion: The appeals succeeded, the High Court's judgment was set aside, and the Board was directed to issue regular appointments with probation and appropriate seniority adjustments.

Ratio Decidendi: A statutory public authority that has made and acted upon clear representations inducing employees to alter their position is bound by promissory estoppel and cannot defeat regularisation by relying on its own service rules.

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