Facts
The petitioners were appointed as coordinators (Preraks) under a Central Government scheme entitled "Sakshar Bharat Karyakram".
Source reference: p. 36-37They served from 2009 until 2017, receiving an initial honorarium of ₹700, later increased to ₹2,000.
Source reference: p. 37On 15.05.2017, the Union of India issued a letter refusing to enhance this honorarium and signaling the potential termination of their employment.
Source reference: p. 36The petitioners approached the High Court seeking absorption into State government employment, an increase in honorarium to minimum wages, and the continuation of their services under successor schemes like "Nav Bharat Saksharta Karyakarm".
Source reference: p. 36-37Issues
Whether the petitioners, appointed on an ad hoc basis under a specific government scheme, are entitled to continued employment or absorption after the scheme's expiration.
Source reference: p. 37-38Whether the respondents are obligated to consider the petitioners’ eight years of experience for appointment under subsequent, similar literacy schemes launched by the State.
Source reference: p. 37-38Law Applied
The Court primarily relied on the principles of service jurisprudence regarding ad hoc appointments under government schemes, as established by the Supreme Court in Mohd. Abdul Kadir and others v. Director General of Police, Assam and others (2009) 6 SCC 611.
Source reference: p. 37This precedent dictates that while ad hoc employees do not have a right to regularization or security of tenure, they should generally be continued as long as the specific scheme remains in force to avoid the "agony and anxiety" of annual terminations.
Source reference: para. 17-18It further establishes that while courts cannot make policy, they can act as catalysts when a change in policy is required to prevent detriment to public interest.
Source reference: para. 20Reasoning
The Court observed that "Sakshar Bharat Karyakram" ended but was replaced by successive schemes: "Padhna Likhna Abhiyan" (2020) and "Nav Bharat Saksharta Karyakarm" (2022), the latter of which is slated to run until 2027.
Source reference: para. 9The Court noted that the petitioners performed their duties for eight years, acquiring significant skills and experience in door-to-door literacy education.
Source reference: para. 9Applying the logic from Mohd. Abdul Kadir, the Court reasoned that while the petitioners cannot claim a right to appointment as a matter of course since the original scheme ended, their experience constitutes an "additional asset" to the State.
Source reference: para. 9Consequently, the Court found it equitable to direct the State to objectively evaluate the petitioners’ suitability for current programs based on their past conduct and the duration of their prior service.
Source reference: para. 10Holding
The High Court disposed of the writ petitions without granting immediate absorption or enhancement of honorarium.
The Court granted the petitioners liberty to submit representations to the Collector and the Rajya Saksharta Samiti Pradhikaran within 30 days.
Source reference: para. 10The competent authorities were directed to decide these representations within 120 days, taking an "objective" view of the petitioners' skills and experience in light of the Supreme Court's directives in Mohd. Abdul Kadir.
Source reference: para. 10Original Court PDF
Heera Paikra & Others v. State of Chhattisgarh & Others [2026:CGHC:10605]
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