Regularisation of temporary public employees must follow vacancy, eligibility, and recruitment rules, not a blanket one-year service formula.

Regularisation policies fixing cut-off dates, requiring Employment Exchange sponsorship, and insisting on prescribed qualifications at initial appointment are treated as valid safeguards against irregular or backdoor entry. A blanket direction to regularise all ad hoc or temporary employees after one year of service is unsustainable because regularisation depends on vacancy position, qualifications, recruitment method, reservation requirements, and service record. Similar broad directions for work-charged employees, daily wagers, casual labourers, and workmen are too general, although existing governmental schemes and appropriate absorption policies may govern eligible cases. A direction for equal pay for equal work must rest on a clear and workable entitlement framework; a vague order is not implementable.

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Issues: (i) whether the conditions in the regularisation policies fixing cut-off dates and requiring Employment Exchange sponsorship were arbitrary or invalid; (ii) whether a blanket direction to regularise all ad hoc or temporary employees after one year of service could be sustained; (iii) whether the directions for regularisation of work-charged employees, daily wagers, casual labourers, and workmen were legally supportable; and (iv) whether the direction on equal pay for equal work could stand.

Issue (i): whether the conditions in the regularisation policies fixing cut-off dates and requiring Employment Exchange sponsorship were arbitrary or invalid.

Analysis: The regularisation orders were issued to meet specific administrative situations and not as general statutory norms. Fixing a date by which the qualifying service had to be completed was held to be a rational method of classifying eligible employees for the purpose of regularisation. The requirement of recruitment through the Employment Exchange or by public advertisement was treated as a legitimate safeguard against back door entry and irregular appointments. The condition that the employee must have possessed the prescribed qualifications at the time of initial appointment was also treated as valid. There was no basis for holding these conditions discriminatory merely because they excluded some employees who did not satisfy them.

Conclusion: The conditions were valid and were not arbitrary or unconstitutional.

Issue (ii): whether a blanket direction to regularise all ad hoc or temporary employees after one year of service could be sustained.

Analysis: The Court held that regularisation cannot be ordered mechanically without reference to vacancy position, qualification, mode of recruitment, reservation requirements, and the service record of the employee. A mere continuation for one year does not by itself establish a right to regularisation. The proper approach is a case-specific consideration under a fair policy framed by the employer, not an unconditional judicial command. Such a blanket direction would also create practical difficulties and could prejudice regularly selected candidates.

Conclusion: The blanket one-year regularisation direction was unsustainable.

Issue (iii): whether the directions for regularisation of work-charged employees, daily wagers, casual labourers, and workmen were legally supportable.

Analysis: Work-charged employees and daily wagers may be entitled to fair consideration for absorption, but not to an unconditional mandate of regularisation in every case. For persons falling within the definition of workman, the protections of industrial law were recognised, but the sweeping directions issued below were still considered too broad. The Court declined to sustain the generalised relief, while noting that regularisation schemes already framed by the Governments would govern many such employees and that the State of Punjab should frame an appropriate absorption scheme for casual labour and daily wagers consistent with available vacancies and service conditions.

Conclusion: The impugned blanket directions for these categories could not be sustained in their entirety.

Issue (iv): whether the direction on equal pay for equal work could stand.

Analysis: The direction was found to be vague and unsupported by any clear discussion as to who was entitled to what wages and on what basis. Without a definite and workable framework, the order could not be implemented meaningfully.

Conclusion: The equal pay direction was set aside.

Final Conclusion: The appeals succeeded, the broad regularisation and equal-pay directions were set aside, and only the limited protection already arising from the existing governmental regularisation policies and schemes was left undisturbed.

Ratio Decidendi: Judicial directions for regularisation of ad hoc or temporary public employment must be shaped by vacancy, eligibility, recruitment method, reservation requirements, and service conditions, and cannot be issued as an unconditional blanket rule on the mere basis of length of service.

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