SYRYA NARAIN YADAV & ORS. versus BIHAR STATE ELECTRICITY BOARD & ORS.

SYRYA NARAIN YADAV & ORS. versus BIHAR STATE ELECTRICITY BOARD & ORS.

The Board is bound to regularise the appointments of trainee engineers who relied on its representations. Promissory estoppel prevents the Board from denying regularisation and seniority, as the appellants altered their positions to their detriment based on assurances of absorption. Appellants must be ranked above 1983 and subsequent recruits but below earlier regular appointees.

Parties
Appellants: S.N. Yadav and others; Respondents: Bihar State Electricity Board and others
Jurisdiction
India
Judgment Date
08 May 1985
Procedural Posture
Civil Appeal / Appeal by Special Leave Against Decision of Patna High Court
Outcome
Appeal allowed; High Court decision reversed.
Legal Topics
Promissory Estoppel, Right to Absorption in Service, Seniority Assignment
Service Law Constitutional Law Promissory Estoppel Right to Absorption in Service Seniority Assignment

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Parties

S.N. Yadav and others

Appellants

Bihar State Electricity Board and others

Respondents

Procedural Posture

Civil Appeal / Appeal by Special Leave Against Decision of Patna High Court

Legal Issues

  1. 1 Applicability of the doctrine of promissory estoppel to State employees
  2. 2 Right to absorption and assignment of seniority based on representations by public body

Ratio Decidendi

The Board is bound to regularise the appointments of trainee engineers who relied on its representations. Promissory estoppel prevents the Board from denying regularisation and seniority, as the appellants altered their positions to their detriment based on assurances of absorption. Appellants must be ranked above 1983 and subsequent recruits but below earlier regular appointees.

Court Disposition

Appeal allowed; High Court decision reversed.

Orders

  • Appellants to be regularised within three months as Assistant/Junior Engineers on probation for two years.
  • Appellants to rank below permanent and temporary recruits to regular posts prior to 1983 and above 1983 and subsequent recruits.