Rakesh Kumar Charmakar vs. State of Madhya Pradesh
Citation: 2025 INSC 136; Civil Appeal Nos. 8613-8614 of 2022
Bench: Justice Vikram Nath, Justice Prasanna B. Varale
Background
This case involved Rakesh Kumar Charmakar and other part-time sweepers employed by the Veterinary Department of Madhya Pradesh under a Special Recruitment Drive. Although engaged on a temporary basis, they were appointed against regular, sanctioned posts and performed duties akin to permanent employees. The appellants sought regular pay scale benefits as per government circulars and the 1979 Rules, arguing that they had completed the requisite period of service and satisfied all conditions for regularization.
Their claim was initially accepted by a Single Judge of the Madhya Pradesh High Court in 2019, but a Division Bench later reversed this, holding them ineligible for regular pay scale benefits. The employees appealed to the Supreme Court, contending that their designation as “part-time” did not affect their entitlement, as they were appointed against sanctioned posts and met all stipulated requirements.
Supreme Court’s Analysis
Eligibility for Regular Pay Scale:
The Supreme Court emphasized that the appellants were recruited through a proper selection process for regular, sanctioned posts. Their status as “temporary” or “part-time” did not detract from the fact that they fulfilled all conditions under the relevant government circulars, including the completion of three years’ service on Collector’s wages with the recommendation of the District Level Recruitment Committee.
Government Accountability:
The Court criticized the State for attempting to deny benefits through delays in convening screening committees or by relying on technicalities. It held that government authorities cannot arbitrarily withhold financial benefits from employees who meet the criteria established by law and policy.
Precedent and Parity:
The Court found that the appellants’ situation was analogous to that of the petitioners in Ram Naresh Prajapati, who were similarly appointed under a Special Recruitment Drive and granted regular pay scale benefits. The Division Bench’s attempt to distinguish the present case was held to be erroneous.
Legal Principle:
The judgment reinforced that temporary or daily wage workers appointed against sanctioned posts are entitled to the same benefits as regular employees once they fulfill the prescribed conditions, and that administrative inaction cannot deprive them of their rights.
Decision
The Supreme Court allowed the appeals, set aside the Division Bench’s judgment, and restored the Single Judge’s order granting regular pay scale benefits to the appellants. The State was directed to ensure compliance and extend all consequential benefits to the employees.
Significance
This ruling is a landmark for contractual and temporary government workers, affirming their right to fair wages and regularization when appointed against sanctioned posts. It prevents arbitrary denial of benefits, strengthens legal protections for underprivileged employees, and compels state authorities to uphold their obligations under established policy and law.
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