Regularization of daily-wage workers must satisfy Article 14 and rest on a valid employer-employee relationship.

Regularization of daily-wage or casual workers cannot be ordered unless a valid employer-employee relationship is established and the result remains consistent with Article 14. The analysis applies the principle in Uma Devi and states that industrial adjudication may vary contractual terms only where it does not produce an unconstitutional outcome. A prior High Court decision made before Uma Devi did not displace the governing constitutional position. On the facts described, the worker was engaged as a daily-wager and not as a regular incumbent holding the claimed post, so the direction for regularization was unsustainable and was set aside.

---

---

Issues: Whether the direction for regularization of the daily-wage workers could be sustained, and whether industrial adjudication could permit such regularization consistently with Article 14 of the Constitution of India.

Analysis: The claim for regularization was examined in the light of the principle laid down in Uma Devi. Though industrial adjudication may vary contractual terms in appropriate cases, it cannot authorise a result that offends Article 14. Regularization presupposes an employer-employee relationship and cannot be granted merely because a worker has been engaged on a casual or daily-wage basis. The fact that the earlier decision of the High Court predated Uma Devi did not alter the governing constitutional principle. On the facts, the worker was found to have been engaged as a daily-wager and not as a regular incumbent holding the claimed post.

Conclusion: The direction for regularization was unsustainable and was set aside; the challenge by the employer succeeded.

Final Conclusion: The judgment reaffirms that regularization cannot be ordered in a manner inconsistent with constitutional equality norms, even in industrial adjudication.

Ratio Decidendi: A direction for regularization of a daily-wage or casual worker cannot be sustained unless it is consistent with Article 14 and the legal basis for a valid employer-employee relationship is established.

---