Facts
The petitioners were appointed as "Preraks" (coordinators) under the Central Government’s "Sakshar Bharat Karyakram" scheme to provide door-to-door education.
Source reference: para 4They served from 2009 until 2017 on an honorarium basis, which was eventually increased to Rs. 2,000/-.
Source reference: para 4On 15.05.2017, the Union of India (Respondent No. 4) issued a letter refusing to enhance the honorarium and effectively threatening the termination of their employment as the scheme was phased out.
Source reference: para 4The petitioners sought quashing of the termination letter, absorption into State government employment, and enhanced honorarium based on minimum wages.
Source reference: para 3While the original scheme ended, it was replaced by subsequent programs: "Padhna Likhna Abhiyan" (2020) and "Nav Bharat Saksharta Karyakram" (2022-2027).
Source reference: para 9Issues
Whether the services of ad-hoc employees appointed under a specific government scheme should be continued or considered for appointment in subsequent schemes of a similar nature.
Source reference: para 4, 7 & 10Whether the petitioners are entitled to an increase in honorarium to match minimum wages and arrears from the date of appointment.
Source reference: para 3Law Applied
The Court primarily applied the principles of service jurisprudence regarding scheme-based employment as established in Mohd. Abdul Kadir v. Director General of Police, Assam (2009) 6 SCC 611.
Source reference: para 4This precedent holds that while ad-hoc employees under a scheme have no right to regularization or security of tenure, they should generally be continued as long as the scheme exists to avoid the "agony and humiliation" of annual terminations.
Source reference: para 4The Court also noted that such appointments are typically co-terminus with the scheme.
Source reference: para 4Reasoning
The Court observed that although the "Sakshar Bharat Karyakram" had officially ended, the Respondent State’s return acknowledged that it had been replaced by the "Nav Bharat Saksharta Karyakram," which involves functions similar in nature and is slated to run from 2022 to 2027.
Source reference: para 9The Court reasoned that the petitioners had acquired "significant skills and experience" through eight years of service (2009–2017), which should be viewed as an "additional asset" for the State.
Source reference: para 9However, since the original scheme had technically concluded and new policies were in place, the Court determined that the appropriate remedy was not a direct order for absorption, but a directed administrative review of the petitioners’ suitability for the current program in light of their prior experience.
Source reference: para 7 & 10Holding
The Court disposed of the writ petitions without granting the specific relief of absorption or wage increase directly.
Instead, it granted liberty to the petitioners to submit a formal representation to the Collector and the Rajya Saksharta Samiti Pradhikaran (Respondents No. 2 and 5) within 30 days.
Source reference: para 10The Court directed the Competent Authority to decide the representation within 120 days, objectively considering the petitioners’ previous experience, skills, and conduct, as well as the legal principles in Mohd. Abdul Kadir.
Source reference: para 10-11Original Court PDF
Heera Paikra & Ors. v. State of Chhattisgarh & Ors. [2026:CGHC:10605]
Click to open original judgment
Original judgment, available to read, download and summarize on LawLens.in