Permanent classification does not equal regularisation; employees were limited to the minimum pay-scale and no extra increments in contempt.

Permanent classification under the Madhya Pradesh Industrial Employment (Standing Orders) Rules, 1963 was treated as distinct from regular appointment or regularisation in service. The Court noted that completion of the prescribed service conditions created permanency under the Rules, but did not confer the full incidents of regular recruitment or regular-service benefits. It further held that, even where equal pay for equal work is relevant, a temporary or merely permanent-classified employee is entitled only to the minimum of the applicable pay-scale unless regularised. Contempt proceedings could not be used to expand the original directions or secure increments not expressly granted, so fixation at the minimum of the regular pay-scale was sufficient compliance.

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Issues: Whether employees classified as permanent under the Madhya Pradesh Industrial Employment (Standing Orders) Rules, 1963 were entitled, in contempt proceedings, to increments and other emoluments in the regular pay-scale or only to the minimum of that pay-scale.

Analysis: The classification of an employee as permanent under the Standing Orders Act and the Rules was held to be distinct from regular appointment or regularisation in service. The scheme of the Rules showed that permanency followed from completion of the prescribed service conditions, while the statutory framework did not confer the rights attached to regular recruitment. The Court relied on earlier decisions distinguishing pay parity from regularisation and held that, even where the principle of equal pay for equal work applies, a temporary or merely permanent-classified employee is entitled only to the minimum of the applicable pay-scale unless regularised. The contempt jurisdiction could not be used to enlarge the original directions or to claim increments not expressly granted.

Conclusion: The Petitioners were not entitled to increments or other regular-service benefits merely because they had been classified as permanent employees; fixation at the minimum of the regular pay-scale was sufficient compliance.

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