Compliance with court-ordered minimum pay scale does not authorize administrative regularization beyond judicial directions.

The petitioner originally obtained a court direction in 2011 for the payment of the minimum of a regular pay scale.

In purported compliance with this and a subsequent writ appeal, the respondent issued an order on September 26, 2015, which not only granted the pay scale but also regularized the petitioner's services.

Upon internal review, higher authorities determined that the regularization exceeded the court's specific directions. Consequently, the respondent issued an impugned order on April 13, 2016, recalling the regularization.

The petitioner challenged this recall, citing a violation of natural justice and the accrual of substantive rights.

1. Whether the recall of the regularization order without a prior hearing violated the principles of natural justice.

2. Whether an administrative order passed in excess of judicial directions confers a substantive right to regularization.

3. Whether the petitioner is entitled to the regular pay scale as opposed to the minimum of the pay scale.

The court applied Article 226 of the Constitution regarding writ jurisdiction.

The court relied on the landmark precedent State of Karnataka v. Uma Devi, which held that temporary or daily-wage employees have no fundamental right to absorption and that regularization must strictly follow constitutional schemes under Articles 14 and 16.

The court further cited Secretary to Government, School Education Department v. R. Govindaswamy, reinforcing that long-term temporary service does not entitle an employee to regularization in the absence of a sanctioned post, and that "litigious employment" under court orders does not confer permanent rights.

The court reasoned that the underlying judicial directions from 2011 only mandated the "minimum of pay scale," not regularization.

The respondent authority acted without jurisdiction by granting regularization in the 2015 order.

The court determined that since the original grant was legally impermissible and exceeded the court's mandate, it did not create any substantive rights for the petitioner.

Regarding the lack of a hearing, the court invoked the "empty formality" doctrine, concluding that providing an opportunity to be heard would not have changed the outcome because the petitioner had no legal basis to claim regularization.

The court emphasized that any regularization must align with established state policy and the Uma Devi framework.

The court directed that the respondents may recover the difference between the "regular" pay scale and the "minimum" pay scale if already paid. The court held that the petitioner is entitled only to the minimum of the pay scale from September 26, 2015, and ordered that any future claim for regularization must be considered strictly in accordance with current government policy.