Legislative cut-off date for regularisation upheld where tied to a valid statutory purpose and rational classification.

A legislative cut-off date for regularisation is valid where it is tied to the expiry of the statutory regime under which ad hoc appointments were lawfully made and bears a rational nexus to the class intended to be regularised. Teachers appointed after 3 January 1984 were treated as a distinct class because, after that date, the management lacked power to continue such appointments outside the limited statutory framework. The classification was therefore not arbitrary or discriminatory, and the provision was upheld as constitutionally valid under Article 14.

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Issues: Whether the fixation of January 3, 1984 as the cut-off date in Section 31B of the U.P. Higher Educational Services Commission Act, 1980 for regularisation of ad hoc teachers was arbitrary or irrational and violative of Article 14 of the Constitution of India.

Analysis: The cut-off date was held to be linked to the expiry of the Removal of Difficulties Orders under which ad hoc appointments had validly been made. After that date, the management had no power to continue making such appointments except within the limited statutory framework. The teachers appointed after January 3, 1984 formed a distinct class from those appointed earlier with legal sanction. The Legislature was therefore entitled to draw a line at the expiry of the relevant Order, and the classification had a reasonable nexus with the object of regularising only those ad hoc appointments that had lawful origin. Comparisons with other regularisation schemes were found inapposite because the statutory settings were materially different.

Conclusion: The cut-off date was not arbitrary or discriminatory, and Section 31B was upheld as constitutionally valid.

Ratio Decidendi: A legislative cut-off date for regularisation is valid if it is linked to a legitimate statutory purpose and has a rational nexus with the class sought to be regularised.

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