Chhattisgarh High Court

### Continuous Service Undertaking Precludes Interference with Contractual/Daily Wage Employment Pending Regularization Consideration

Shailesh Dewangan & Others v. State of Chhattisgarh & Others [2026:CGHC:10988-DB]

Chhattisgarh High CourtJUDGMENT: no citation2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The appellants, qualified individuals appointed on a daily wage basis, have served the Municipal Corporation, Dhamtari, for over 15 years, performing clerical and administrative duties

Source reference: p. 5-6

Despite the availability of 29 vacant Class IV posts, the respondents issued a notice dated 21.04.2015 to hire placement agencies/labour contractors to supply manpower for the same roles

Source reference: p. 6

The appellants challenged this notice and the refusal of regularization in a writ petition, which was dismissed by a Single Judge on 26.09.2025

Source reference: p. 6

The present writ appeals challenge the Single Judge's dismissal, seeking quashment of the contractor advertisement and consideration for regularization

Source reference: p. 6
02

Issues

1. Whether the appellants, having served for nearly 15 years, possess a legitimate expectation for fair consideration for regularization against vacant Class IV posts

Source reference: p. 6-7

2. Whether the Municipal Corporation’s decision to replace daily wage employees with contract labour via placement agencies is arbitrary and detrimental to the public exchequer

Source reference: p. 7

3. Whether the grievances of the appellants can be resolved based on the Corporation's subsequent undertaking to retain them in service

Source reference: p. 8-9
03

Law Applied

The Court applied the principle of Legitimate Expectation and the doctrine of Fair Consideration in matters of regularization of long-term temporary employees

Source reference: p. 6-7

It relied on the procedural mechanism of Undertakings and Affidavits filed by State instrumentalities to resolve service disputes

Source reference: p. 7-8

The court maintained the distinction between the right to continue in service and the right to Regularization, noting that the latter must be governed by specific recruitment rules and applicable law

Source reference: p. 9
04

Reasoning

The Court analyzed the matter primarily through the lens of the affidavit filed by the Commissioner of the Municipal Corporation, Dhamtari, on 01.03.2026

Source reference: p. 7

The Corporation affirmed that 25 of the remaining 28 employees were still working and would be permitted to continue in their respective posts as they were prior to the 2015 advertisement

Source reference: para. 9-10, p. 8

The Court observed that this undertaking effectively addressed the primary grievance regarding the immediate threat of displacement by contractors

Source reference: p. 8-9

However, the Court exercised judicial restraint by refusing to adjudicate on the merits of the Single Judge’s order or the absolute right to regularization, instead binding the Corporation to its statement that "necessary administrative steps shall be taken forthwith" to implement the court's directions in spirit

Source reference: para. 11, p. 8-9
05

Holding

The High Court disposed of the writ appeals in terms of the respondent’s affidavit

The Court held that the primary grievance was substantially addressed by the Corporation's commitment to allow the appellants to continue in service

Source reference: p. 8-9

The respondents were directed to strictly adhere to their undertaking

Source reference: p. 9

The Court clarified that this order does not confer an automatic right of regularization; rather, the appellants’ claims for regularization must be considered independently in accordance with applicable rules and law

Source reference: p. 9
Chhattisgarh High Court

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Shailesh Dewangan & Others v. State of Chhattisgarh & Others [2026:CGHC:10988-DB]

Chhattisgarh High Court · no citation

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