State must objectively consider regularizing daily wagers completing a decade of continuous service.

The 18 petitioners were engaged as daily wage employees (occupying roles such as Computer Operators, Office Assistants, and Surksha Shramik) within the Forest Department of Chhattisgarh between 2006 and 2016.

Having completed over a decade of continuous service at collector rates, the petitioners sought regularization of their services.

They filed the present writ petition seeking directions for the State to consider their regularization and frame guidelines for employees appointed after the formation of the State of Chhattisgarh, citing various Supreme Court precedents.

The State opposed the petition, contending that the petitioners were not covered under the Regularization Circular dated 05.03.2008.

1. Whether the petitioners are entitled to be considered for regularization of their services after completing more than ten years of continuous daily wage employment.

2. Whether the State's reliance on the 2008 Circular and previous restrictive judgments is sustainable in light of recent Supreme Court jurisprudence regarding "ad-hocism".

The Court relied on the framework for regularization established in Secretary, State of Karnataka v. Umadevi (3) [(2006) 4 SCC 1] and expanded in Narendra Kumar Tiwari v. State of Jharkhand [(2018) 2 SCC (L&S) 472], which permits regularization for employees completing 10 years of service.

The Court further applied Jaggo v. Union of India [(2024) SCC Online SC 3826], emphasizing the State’s duty as a model employer.

The Court applied Bhola Nath v. State of Jharkhand (2026), which held that long-term contractual engagement on sanctioned posts should not bar regularization.

Finally, the Court applied Dharam Singh v. State of UP (2025 SCC OnLine SC 1735), which deprecated the practice of "ad-hocism" and held that the State cannot balance budgets by maintaining perennial workers under temporary labels.

The Court noted that the petitioners have served for over a decade and have likely exceeded the age limit for other employment.

It distinguished the State’s reliance on Premsagar Chouhan v. State of Chhattisgarh, noting that the cited case involved employees whose services had been discontinued, whereas the current petitioners are still continuously working.

The Court reasoned that the State, as a "constitutional employer," must reflect the reality of recurring work in its sanctioned strength rather than exploiting regular labor under temporary labels.

Following the logic in Dharam Singh, the Court emphasized that fairness, reason, and constitutional discipline (Articles 14, 16, and 21) require the State to organize perennial workers on a sanctioned footing rather than through "opaque" ad-hoc arrangements.

Consequently, the Court found the petitioners’ claim for a fresh objective review to be meritorious.

The respondents were directed to consider and decide the claim for regularization "sympathetically in an objective manner" within four months of receipt.

The Court mandated that this consideration must be guided by the principles laid down in Narendra Kumar Tiwari, Jaggo, Bhola Nath, and Dharam Singh.