Punjab & Haryana HC: Regularization Claim Filed After Two Decades Dismissed, Appeals Rejected for Delay and Laches

 Case Name: Anand Singh v. State of Haryana & Ors.; Satish Kumar & Ors. v. State of Haryana & Ors.; Mahabir Singh & Anr. v. State of Haryana & Ors.; Shri Krishan v. State of Haryana & Ors.
Date of Judgment: January 14, 2020
Citation: LPA Nos. 50, 46, 51 and 58 of 2020 (O&M)
Bench: Hon’ble Chief Justice Mr. Justice Ravi Shanker Jha and Hon’ble Mr. Justice Arun Palli

Held: The High Court dismissed a batch of intra-court appeals challenging the rejection of regularization claims, holding that the writ petitions were barred by delay and laches. The appellants, whose services had been regularized in the 1990s and early 2000s, raised disputes nearly 15–20 years later seeking regularization from an earlier date based on government instructions of 19.02.1979. The Court held that such stale claims could not be entertained, particularly when the appellants had accepted benefits of regularization for decades. It relied on Sukhbir Singh v. State of Haryana (LPA No. 1662 of 2015) and State of UP v. Arvind Kumar Srivastava (2015) 1 SCC 347, reiterating that “fence-sitters” who wake up after long inaction cannot claim parity under Article 14.

Summary: The lead case involved Anand Singh, appointed as Helper-cum-Mechanic in 1989 and regularized in 1996. In 2013, after nearly two decades, he served a notice claiming regularization from the date he completed 240 days of service in 1989, relying on instructions of 19.02.1979. His claim was rejected in 2014, but he filed a writ only in 2017, which was dismissed for laches. Similar facts applied to the other connected appellants, Satish Kumar, Mahabir Singh, and Shri Krishan, whose services had been regularized in 2003–2004 but who raised claims for earlier regularization after 14–16 years. The Court observed that such belated challenges, even if based on earlier policies or judgments in favour of others, could not be reopened after decades. It rejected reliance on cases like Surat Singh v. State of Haryana and Santosh Kumari v. Union of India, holding them inapplicable in the face of inordinate delay. It also noted that the 1979 instructions applied only to conductors, drivers, and workshop staff engaged through Employment Exchange who had completed 240 days as of 19.02.1979, which did not cover the appellants.

Decision: The High Court upheld the dismissal of the writ petitions and rejected all connected Letters Patent Appeals, holding the claims barred by delay and laches and finding no merit in reopening old cases of regularization.