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Supreme Court of India· 16 April 2026

Does the "one time measure" directed in Umadevi lapse once the six month period from that decision has expired?

MADAN SINGH AND OTHERS v. STATE OF HARYANA
2026 INSC 379 · CIVIL APPEAL NO.1996 OF 2024
Coram: Atul S. Chandurkar; Pamidighantam Sri Narasimha
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Answer

No. The one time exercise is concluded only when all the employees who are entitled to be considered in terms of Umadevi are so considered. That the employer did not undertake the exercise within six months, or undertook it only in regard to a limited few, will not disentitle such employees the right to be considered for regularisation.

Headnote

Constitution of India — Arts. 16 and 142 — Regularisation of ad hoc, contractual and daily wage employees — "One time measure" — Sanctioned vacant post — Advertisement and interview — Future cut-off date — Lowest pay scale — Constitution of India — Art. 16 — Policy reviving an earlier withdrawn regularisation policy — Validity — Held: A policy extending regularisation to ad hoc employees left out of an earlier withdrawn policy is valid where the criteria prescribed are not in any manner watered down from those for regular appointment. Initial engagement on a sanctioned vacant post continuing at the time of regularisation, with the prescribed qualification, is not arbitrary. (¶18, 20) Constitution of India — Art. 16 — Regularisation without advertisement or interview — Future cut-off date — Held further: Regularising ad hoc employees engaged without any advertisement and without facing any interview is arbitrary and illegal, the absence of any record of the manner of engagement inspiring no confidence. A future cut-off date beyond four years means posts which could have been filled in through regular recruitment are not liable to be advertised. (¶21) Constitution of India — Art. 142 — "One time measure" under Umadevi — Continuation at lowest pay scale — Held further: The one time exercise directed in Umadevi concludes only when every employee entitled to be considered is so considered, and expiry of the six month period does not disentitle him. Employees continuing under the struck down notifications may continue at the lowest pay scale under Article 142. Appeals disposed of. (¶19, 23)

In the Court's own words
Paragraph 19Much emphasis has been placed on the aspect that despite the policy of regularisation being required to be undertaken as an “one time measure” as enunciated in paragraph 44 of the decision in Umadevi (supra), the State Government sought to undertake this exercise of regularisation belatedly and in a perpetual manner. In this regard, we may usefully refer to observations of this Court in M L Kesari (supra) wherein this aspect has been clarified. In paragraphs 5 to 8 of the said decision, it has been held as under:
Acts & Sections
Art. 16 Constitution of IndiaArt. 14 Constitution of IndiaArt. 142 Constitution of IndiaArt. 309 Constitution of IndiaArt. 162 Constitution of India

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Also decided in this judgment
Is a policy regularising ad hoc employees valid where it merely extends an earlier withdrawn policy to those left out, on the same criteria?Is a policy regularising ad hoc employees engaged without any advertisement and without facing any interview arbitrary and illegal?
Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Supreme Court of India. Corrections