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2026 Supreme(SC) 410

SUPREME COURT OF INDIA
PAMIDIGHANTAM SRI NARASIMHA, ATUL S. CHANDURKAR, JJ.
Madan Singh and Others – Appellants
Versus
State of Haryana and Others – Respondents
Civil Appeal No. 1996 of 2024 With Civil Appeal No. 2031 OF 2024 Civil Appeal No. 2033 of 2024 Civil Appeal No. 2041 of 2024 Civil Appeal Nos.2035-2037 of 2024 Civil Appeal Nos.2099-2100 of 2024 Civil Appeal No. 2044 of 2024 Civil Appeal Nos. of 2026 (@ SLP (C) Nos. of 2026) (@ Diary No. 50483 of 2023) Civil Appeal No. 2000 of 2024 Civil Appeal No. 1997 of 2024 Civil Appeal No. 1998 of 2024 Civil Appeal No. 2008 of 2024 Civil Appeal No. 1999 of 2024 Civil Appeal Nos.2004-2006 of 2024 Civil Appeal No. 2001-2003 of 2024 Civil Appeal No. 2007 of 2024 Civil Appeal Nos.2010-2021 of 2024 Civil Appeal No. 2009 of 2024 Civil Appeal No. 2025 of 2024 Civil Appeal Nos.2022-2023 of 2024 Civil Appeal No. 2024 of 2024 Civil Appeal No. 2026 of 2024 Civil Appeal Nos.2027-2028 of 2024 Civil Appeal No. 2029-2030 of 2024 Civil Appeal No. 2040 of 2024 AND Civil Appeal No. of 2026 (@ SLP (C) No. 18125 of 2025)
Decided On : 16-04-2026

Advocates appeared:
For the Appellant(s) : Mr. B Adi Narayan Rao, Sr. Adv. Mr. Ravi Prakash Mehrotra, Sr. Adv. Mr. Lok Pal Singh, Sr. Adv. Mr. Bharpur Singh, Adv. Mr. Akash, Adv. Dr. Amardeep Gaur, Adv. Mr. Divyanshu Sahay, Adv. Mr. Saurabh Arora, Adv. Mr. Mukesh Kumar, Adv. Mr. Vinay Kumar Sah, Adv. Mr. Ahutosh Bhardwaj, Adv. Mr. Prateek Rai, Adv. Mr. Srikant Singh, Adv. Mr. Srajan S Kulshrestha, Adv. Mr. Anurag Pandey, Adv. M/s V. Maheshwari & Co., AOR Mr. Dinesh Kumar Garg, AOR Mr. Shivam Singh, Adv. Mr. Ravi Shanker Jha, Adv. Mr. Yoshit Jain, Adv. Ms. Pooja, Adv. Mr. Vishal Arun Mishra, AOR Mr. Himanshu Sharma, AOR Mr. Sandeep Singh, Adv. Ms. Aditi Sharma, Adv. Mr. Arun Kumar Raghav, Adv. Mr. Digvijay Singh Raghav, Adv. Ms. Kamlesh, Adv. Ms. Anjali, Adv. Mr. Varun Sharma, Adv. Ms. Richa Attrey, Adv. Mr. Hari Shankar Rajvans, Adv. Mr. Narender Singh, Adv. Ms. Jyoti Rajvansh, Adv. Mr. Rameshwar Prasad Goyal, AOR Mr. Deepak Goel, AOR Mr. Lokesh Sinhal, A.A.G. Mr. Arun Bhardwaj, Sr. Adv. Dr. Monika Gusain, Sr. Adv. Ms. Karishma Malani, A.A.G. Mr. Akshay Amritanshu, AOR Mr. Hariom Yaduvanshi, Adv. Mr. Nikunj Gupta, Adv. Mr. Arjun Yaduvanshi, Adv. Ms. Ishika Gupta, Adv. Mr. Hari Om Yaduvanshi, Adv. Ms. S. Harini, Adv. Ms. Aakanksha, Adv. Mr. Arjun Yadhuvanshi, Adv. Ms. Drishti Rawal, Adv. Ms. Sarthak Arya, Adv. Ms. Neha Mishra, Adv. Mr. Sarthak Srivastava, Adv. Mr. Mayur Goyal, Adv. Ms. Seema Sindhu, Adv. Mr. Vansmani Tripathi, Adv. Ms. Kirti, Adv. Ms. Richa Verma, Adv. Mr. Samar Vijay Singh, AOR Mr. Siddharth Mittal, AOR Mr. Abhijeet Varshney, Adv. Mr. Sumit Kumar Sharma, Adv. Mrs. Shilpa G Mittal, Adv. Mr. Atul Kumar, Adv. Mr. Abhimanyu Sharma, Adv. Ms. Deepali Atreja, Adv. Mr. Rahul Thukral, Adv. Mr. Manish Chaurasia, Adv. Mr. S. K. Verma, AOR Mr. Jasbir Singh Malik, Adv. Ms. Prachi Sohi, Adv. Ms. Pooja Devi, Adv. Mr. Varun Punia, AOR Mr. Shish Pal Laler, Adv. Mr. Hitesh Kumar, Adv. Mr. Atul, Adv. Mr. Vedant Pradhan, Adv. Mr. Hardik Giri, Adv. Mr. Pranav Singh Gautam, Adv. Mr. Naman Singh, Adv. Mr. R. C. Kaushik, AOR Mr. Pardeep Gupta, Adv. Mr. Parinav Gupta, Adv. Mrs. Mansi Gupta, Adv. Mr. Rakshit Rathi, Adv. Mr. Shadab Khan, Adv. Dr. Mrs. Vipin Gupta, AOR Mr. Krishna Kumar, Adv. Mr. Ram Naresh Yadav, AOR Mr. Sarvesh Kumar Yadav, Adv. Mr. Suryavir, Adv. Mr. Satyendra Kumar, AOR Dr. Sudhir Bisla, Adv. Mrs. Sumitra Bisla, Adv. Mr. Roshan Singh Thakur, Adv. Mr. Subhasish Bhowmick, AOR Mr. Kv Jagdishvaran, Adv. Ms. Malika Agarwal, Adv. Ms. G. Indira, AOR Mr. P Gandepan, Adv. Ms. Anjali Singh, Adv. Ms. Amrita Kumari, Adv. Ms. Raniba Pangnila, Adv. Ms. Amrit Kaur, Adv. Ms. Preeti Singh, AOR Mr. Roopansh Purohit, AOR Mr. Harsh Panwar, Adv. Ms. Narayani Sepaha, Adv. Mr. Haresh Raichura, AOR Mr. Rishi Malhotra, Sr. Adv. Ms. Ansuiya, Adv. Mr. Shivaansh Maini, Adv. Mr. Prem Malhotra, AOR Mr. Abhimanyu Tewari, AOR Mr. Siddhant Saroha, Adv. Mr. Sudhant Awasthy, Adv. Mr. Aniket Kumar Parcha, Adv. Mr. Kartik Jasra, Adv. Mr. Shivam Jasra, AOR Ms. Vidhi Sharma, Adv. Mr. Shivam Nagpal, Adv. Mr. Nakul Khanna, Adv. Mr. Hari Pratap Singh, Adv. Mr. Shish Pal Laler, Adv. Mr. Hitesh Kumar, Adv. Mr. Hardik Giri, Adv. Mr. Naman Singh, Adv. Ms. Preeti Kumari, Adv. Mr. Naveen, Adv. Mr. Shivam Sharma, Adv. Mr. Sanjay Maurya, Adv. Mr. Mohit Mathur, Adv. Mr. Ravi Panwar, AOR Mr. Ram Bhadauria, Adv. Mr. Robin Khokhar, AOR Ms. Ritu Reniwal, Adv. Mr. B.n. Dubey, Adv. Mr. Shekhar Chandra, Adv. Ms. Khushi Thawal, Adv. Ms. Esha Thawal, Adv. Mr. Ranvir Singh, AOR
For the Respondent(s): Mr. Nidhesh Gupta, Sr. Adv. (Amicus Curiae) Assisted by :- Ms. Japneet Kaur, Adv. Ms. Jhanvi Dubey, Adv. Mr. Ashok Mathur, AOR Ms. Vriti Gujral, Adv. Mr. Bikram Dwivedi, Adv. Mr. Jimut Mohopatra, Adv. Mr. Jasbir Singh Malik, Adv. Ms. Prachi Sohi, Adv. Ms. Pooja Devi, Adv. Mr. Varun Punia, AOR Mr. Sarthak Ghonkrokta, AOR Mr. Samar Vijay Singh, AOR Ms. Sabarni Som, Adv. Mr. Aman Dev Sharma, Adv. Mr. Gaj Singh, Adv. Mr. Pushkar Sharma, Adv. Ms. Baani Khanna, AOR Mr. Robin Singh, Adv. Mr. Kapil Balwani, Adv. Mr. Shrikant T., Adv. Mr. Satyendra Kumar, AOR Dr. Sudhir Bisla, Adv. Mr. Harikesh Singh, Adv. Mrs. Sumitra Bisla, Adv. Mr. Roshan Singh Thakur, Adv. Mr. Sandeep Sinhmar, Adv. Ms. Amita Dhiman, Adv. Ms. Roopa Paul, Adv. Mr. Parveen Paul, Adv. Mr. Arun Bhardwaj, Sr. Adv. Dr. Monika Gusain, Sr. Adv. Mr. Akshay Amritanshu, AOR Ms. S. Harini, Adv. Mr. Hariom Yaduvanshi, Adv. Ms. Neha Mishra, Adv. Mr. Neha Mishra, Adv. Avi Dhankar, Adv. Ms. Tanya Gupta, Adv. Mr. Arjun Yaduvanshi, Adv. Mr. Hari Om Yaduvanshi, Adv. Mr. Arjun Yadhuvanshi, Adv. Mr. Vansmani Tripathi, Adv. Ms. Drishti Rawal, Adv. Mr. Sarthak Srivastava, Adv. Mr. Mayur Goyal, Adv. Mr. D. Vidyanandam, Adv. Mr. Vipin Kumar Jai, AOR Mr. John Mathew, AOR Dr. Nirmal Chopra, AOR Mr. John Mathew, Adv. Mr. K V Jagdishvaran, Adv. Ms. G. Indira, AOR Mr. P Gandepan, Adv. Ms. Amrita Kumari, Adv. Ms. Anjali Singh, Adv. Ms. Raniba Pangnila, Adv. Ms. Amrit Kaur, Adv. Mr. Dhananjay Garg, AOR Mr. Shekhar Mehla, Adv. Mr. Jatin Bhardwaj, AOR Ms. Madhu Moolchandani, AOR Mrs. S. Janani, Sr. Adv. Ms. Aakriti Jain, AOR Mr. D. S. Matya, Adv. Ms. Palak Goel, Adv. Mr. Akash Rana, Adv. Mr. Udian Sharma, AOR Mr. Manav Mitra, Adv. Mr. Vibhuti Sushant Gupta, Adv. Mr. Keane Sardhina, Adv. Mr. Narender Kumar Verma, AOR Mr. Subodh Kumar Pathak, Adv. Mr. Vinod K. Soni, Adv. Mr. R. P. Wadwani, Adv. Mr. Ansar Ahmad Chaudhary, AOR Mr. Ranvir Singh, AOR Mr. Piyush Sharma, AOR Mr. Anuj Kumar Sharma, Adv. Mr. Arjunsanjay, Adv. Mr. Aditya Dikshit, Adv. Mr. Shish Pal Laler, Adv. Mr. Hitesh Kumar, Adv. Mr. Vedant Pradhan, Adv. Mr. Hardik Giri, Adv. Mr. Varun Tokas, Adv. Mr. Mohit, Adv. Mr. Ravi Panwar, AOR Ms. Mallika Agarwal, Adv. Mrs. S. Janani, Sr. Adv. Ms. Madhu Moolchandani, AOR Mr. Sunil Kumar Nehra, Sr. Adv. Mr. Harshit Sethi, Adv. Mr. Rahil Mahajan, Adv. Ms. Manasi Tripathi, Adv. Mr. Kartik Yadav, Adv. Mr. Kunal Verma, AOR Mr. John Mathew, Adv. Mr. K V Jagdishvaran, Adv. Ms. G. Indira, AOR Mr. P Gandepan, Adv. Ms. Amrita Kumari, Adv. Ms. Anjali Singh, Adv. Ms. Raniba Pangnila, Adv. Ms. Amrit Kaur, Adv. Mr. S. Janani, Sr. Adv. Mr. Deepak Goel, AOR Ms. Alka Goyal, Adv. Ms. Archana Preeti Gupta, Adv. Mr. Nishant Kumar, Adv. Mr. Rao Ranjit, AOR Mr. Siddharth Batra, AOR Ms. Archna Yadav, Adv. Mr. Karan Singh Narang, Adv. Ms. Seema, Adv. Mr. Chinmay Dubey, Adv. Ms. Shivani Chawla, Adv. Mr. Ashutosh Chugh, Adv. Mr. Pankaj Kumar, AOR Dr. Nirmal Chopra, AOR Mr. Ashish Pandey, AOR Mr. Akash, Adv. Mr. Srajan S. Kulshrestha, Adv. Mr. Anurag Pandey, Adv. Mr. Bharpur Singh, Adv. Mr. Ram Naresh Yadav, AOR Mr. Sarvesh Kumar Yadav, Adv. Mr. Chritarth Palli, Adv. Mr. Sahil Tagotra, AOR Mr. Narender Hooda, Sr. Adv. Ms. Pallvi Hooda, Adv. Mr. Shiv Bhatnagar, Adv. Mr. Yuvraj Nandal, Adv. Ms. Kavya Manuja, Adv. Ms. Tannu, Adv. Mr. Shaurya Lamba, Adv. Dr. Surender Singh Hooda, AOR Mr. R. D. Narwal, Adv. Mr. F. I. Choudhury, AOR Mr. B. K. Satija, AOR Mr. Chritarth Palli , AOR Mr. Ravi P. Wadhwani, AOR Mr. Rabin Majumder, AOR Mr. Ashish Pandey, AOR

Notifications aimed at regularizing ad hoc employees must comply with established recruitment laws and principles; ongoing regularization is not permissible without adhering to statutory procedures.

Headnote:(A) Constitution of India - Articles 162 and 309 - Validity of Notifications for regularization of services of contractual/ad hoc employees - Notifications dated 16.06.2014 and 18.06.2014 found valid; Notifications dated 07.07.2014 struck down as arbitrary and illegal - Policy decisions were found to be in breach of Umadevi (2006) principles. (Paras 21-25)

(B) Regularization - It cannot be an ongoing process, post-Umadevi should not allow violation of recruitment rules - State government failed to justify reliance on executive power without conducting proper recruitment. (Paras 17-18)

Facts of the case:
The appellants contested the legality of Notifications by Haryana's General Administration Department intended to regularize the services of Group 'B', 'C', and 'D' contractual employees post Umadevi ruling. High Court ruled these Notifications were illegal, leading to appeals.

Findings of Court:
Notifications dated 16.06.2014 and 18.06.2014 validated; the 07.07.2014 Notifications perpetuated illegality thus invalidated.

Issues: Legality of notifications regarding employee regularization in light of established constitutional principles; adherence to requirements set by Umadevi ruling.

Ratio Decidendi: Notifications 16.06.2014 and 18.06.2014 aligned with legal principles by ensuring eligibility based on qualifications and sanctioned posts; Notifications 07.07.2014 failed by not adhering to stipulated processes.

Result: Appeals partly allowed; Notifications dated 16.06.2014 and 18.06.2014 upheld; Notifications dated 07.07.2014 quashed. Employees under regularization retained in lowest pay scale until new recruitment processes established.

Judgement Key Points

Key Points: - The High Court held Notifications 16.06.2014 and 18.06.2014 to be in line with Umadevi-related principles and not arbitrary; 07.07.2014 found arbitrary and illegal. (!) (!) - The Supreme Court upheld the validity of 16.06.2014 and 18.06.2014, and quashed 07.07.2014, while permitting continued ad hoc employees under 07.07.2014 to remain in the lowest pay scale under Article 142 and Jagjit Singh principles. (!) (!) (!) - Umadevi (2006) introduces the concept of a "one-time measure" to regularize ten-year or more ad hoc employees against sanctioned vacancies, with strict eligibility criteria. (!) (!) - The judgment clarifies that regularization cannot be a perpetual process and must adhere to recruitment rules; executive power cannot override statutory recruitment norms. (!) (!) - Ad hoc employees who were regularized under 07.07.2014 are struck down for regularization under that scheme, but those who benefited under 16.06.2014 and 18.06.2014 are protected, subject to verification. (!) (!) - The Court leaves open certain contentions for future cases under Article 142 to achieve justice. (!)

What is the legality of Haryana's Notifications 16.06.2014 and 18.06.2014 regarding regularization of contractual/ad hoc/daily wage employees?

What is the legality of Haryana's Notifications 07.07.2014 seeking to regularise ad hoc employees with a future cut-off date of 31.12.2018?

What are the limits on regularization under Umadevi (2006) and Kesari decisions, and how do they apply to continued ad hoc employees in this case?

Table of Content
1. process of employee regularization in haryana. (Para 3 , 4 , 5 , 6)
2. high court's quashing of notifications. (Para 7 , 8)
3. appeals against high court's judgment. (Para 9)
4. arguments from appellants and respondents. (Para 10 , 11 , 12)
5. court's evaluation of notifications. (Para 17 , 18 , 20 , 21)
6. clarification on one-time regularization. (Para 23)
7. court's final order and judgment. (Para 24 , 25 , 26 , 27)

JUDGMENT :

ATUL S. CHANDURKAR, J.

1. Delay, if any, is condoned in Diary No. 50483 of 2023.

2. Leave granted in the Special Leave Petitions.

3. In this batch of appeals, we are called upon to determine the correctness of the common judgment of the Division Bench of the Punjab and Haryana High Court¹ [For short “the High Court”] dated 31.05.2018 rendered in a batch of writ petitions. By the said judgment, the policy decisions of the General Administration Department of the State of Haryana dated 16.06.2014, 18.06.2014 and 07.07.2014 seeking to regularise the services of various contractual/ad hoc/daily wage employees falling in Group ‘B’, ‘C’ and ‘D’ have been found to be violative of the law laid down by this Court. Accordingly, the said Notifications have been quashed. In some appeals, the appellants are aggrieved by the denial of the relief of regularisation.

A. Factual Backdrop:

4. In the matter of recruitment to the posts of Assistant Professors and various other categories of employees falling in Group ‘B’, ‘C’, and ‘D’, the State of Haryana through its General Administration Department undertook the exercise of engagement of employees on contractual or ad hoc basis, as per the contingencies arising. In that regard, pursuant to the judgment in the case of Secretary, State of Karnataka and Others vs. Umadevi and Others , 2006 INSC 216, Notification dated 29.07.2011 came to be issued seeking to regularise the services of employees, who had worked for not less than ten years as on 10.04.2006 and were continued in service without the aid of any interim order passed by any Tribunal or Court. In the said policy, it was stated that such regularisation was being undertaken as an ‘one time measure’. Thereafter, on 16.06.2014 another Notification came to be issued proposing to regularise the services of Group ‘B’ employees working on contractual basis, who were in service as on 28.05.2014 and had been working for not less than three years on that date. It was stated that this was being done as an ‘one time measure’ on humanitarian ground and that in future no such appointments would be made against sanctioned posts.

5. Subsequently, on 18.06.2014 another Notification with regards to Group ‘C’ and ‘D’ employees with a similar dateline came to be issued so as to regularize their services.

6. Thereafter on 07.07.2014, another Notification seeking to regularise the services of Group ‘B’ employees who had or would complete ten years’ service on 31.12.2018 came to be issued, again by way of an ‘one time measure’ on humanitarian ground. On the same day, another Notification with regard to Group ‘C’ and ‘D’ employees also came to be issued with a similar dateline.

B. Judgment of the High Court:

7. The aforesaid Notifications dated 16.06.2014, 18.06.2014 and 07.07.2014 were the subject matter of challenge in Writ Petition No. 17206 of 2014 by respondent Nos.4 and 5 in Civil Appeal No. 1996 of 2024. Another batch of petitioners working on ad hoc basis sought the relief of regularisation in their writ petitions. The High Court considered all the writ petitions together and proceeded to hold that the impugned Notifications were bad in law inasmuch as they had the effect of violating the law laid down by this Court in its various decisions in the matter of regularisation of services of contractual/ad hoc/daily wage employees. It held that failure to resort to regular mode of recruitment after the judgment in Umadevi (supra) could not be treated as an administrative exigency. The advertisements issued had invited applications f

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2026 Supreme(SC) 410

Notifications aimed at regularizing ad hoc employees must comply with established recruitment laws and principles; ongoing regularization is not permissible without adhering to statutory procedures.

What is the legality of Haryana's Notifications 16.06.2014 and 18.06.2014 regarding regularization of contractual/ad hoc/daily wage employees?

What is the legality of Haryana's Notifications 07.07.2014 seeking to regularise ad hoc employees with a future cut-off date of 31.12.2018?

What are the limits on regularization under Umadevi (2006) and Kesari decisions, and how do they apply to continued ad hoc employees in this case?

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