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Contract employees

Contract employees legal meaning, translation and judicial precedents.

Meaning & Judicial Interpretation: (اردو مفہوم اور قانونی تشریح)

2025 SCMR 104 SUPREME-COURT Judicial Precedent
Contract employeesRegularization of posts in BS-16 and aboveCabinet Sub-Committee, powers ofScopeRules of Business, 1973, were duly framed to conduct the business of the Federal Government

Under these rules, although there is a concept of Cabinet Sub-Committees on different subjects, there is no provision for the intervention of a Cabinet Sub-Committee in governing the terms and conditions of service of employees

However, the Cabinet Sub-Committee can recommend reforms in the service structure, which can be approved by the Cabinet in accordance with the law and the Constitution

As, the Cabinet Sub-Committee lacks the authority to recommend the regularization of posts in BS-16 and above, therefore, any recommendation by the Cabinet Sub-Committee to regularize appointments in BS-16 and above is void ab initio and without any lawful authority.

2025 SCMR 104 SUPREME-COURT Judicial Precedent
Contract employeesRegularization in serviceScope

Regularization of a contractual employee constitutes a fresh appointment into the stream of regular appointments in civil services.

2025 SCMR 104 SUPREME-COURT Judicial Precedent
Contract employeesRegularization in serviceFactors to be considered by an employer/institution opting for regularization of its contract employees

Any institution opting for regularization of its employees must be either mandated by law or must carry out regularization through a well-thought-out policy of the institution concerned laying down the criteria and the process for regularization; performance evaluation of the contractual employee must be assessed to determine if the employee meets the standards required for a regular position; there must be availability of positions that match the skills and experience of the contractual employee; the budgetary considerations and financial implication of a regular employee must be weighed and considered

There must be a fair assessment of the employee's qualifications, performance and merit, so as to ensure only competent and committed employees are granted permanent employment status.

2025 PLC(CS) 154 SUPREME-COURT Judicial Precedent
Contract employeesRegularization in serviceFactors to be considered by an employer/institution opting for regularization of its contract employees

Any institution opting for regularization of its employees must be either mandated by law or must carry out regularization through a well-thought-out policy of the institution concerned laying down the criteria and the process for regularization; performance evaluation of the contractual employee must be assessed to determine if the employee meets the standards required for a regular position; there must be availability of positions that match the skills and experience of the contractual employee; the budgetary considerations and financial implication of a regular employee must be weighed and considered

There must be a fair assessment of the employee's qualifications, performance and merit, so as to ensure only competent and committed employees are granted permanent employment status.

2025 PLC(CS) 154 SUPREME-COURT Judicial Precedent
Contract employeesRegularization in serviceScope

Regularization of a contractual employee constitutes a fresh appointment into the stream of regular appointments in civil services.

2025 PLC(CS) 154 SUPREME-COURT Judicial Precedent
Contract employeesRegularization of posts in BS-16 and aboveCabinet Sub-Committee, powers ofScopeRules of Business, 1973, were duly framed to conduct the business of the Federal Government

Under these rules, although there is a concept of Cabinet Sub-Committees on different subjects, there is no provision for the intervention of a Cabinet Sub-Committee in governing the terms and conditions of service of employees

However, the Cabinet Sub-Committee can recommend reforms in the service structure, which can be approved by the Cabinet in accordance with the law and the Constitution

As, the Cabinet Sub-Committee lacks the authority to recommend the regularization of posts in BS-16 and above, therefore, any recommendation by the Cabinet Sub-Committee to regularize appointments in BS-16 and above is void ab initio and without any lawful authority.

2025 PLC(CS) 1029 LAHORE-HIGH-COURT-LAHORE Judicial Precedent
Contract employeesDate of regularizationWhether date of regularization would operate from the date of regular appointmentSeniority and EmolumentsEntitlement and ComputationRegular and contractual appointmentsDistinction

Facts of the case, in brevity, were that the petitioners were appointed on contract in 2007 in the 'Prosecution Service of Punjab' and their services were terminated later but the High Court held that they were entitled to regularization under the government's notification dated 10.11.2010

They were eventually appointed on a regular basis in 2022, but their appointments were treated as fresh appointments, whereas, the petitioners sought regularization from the dated of notification dated 10.11.2010 for seniority and benefits

Question before the High Court was as to "whether the date of regularization of the petitioners (employees) should be considered as 10.11.2010 (the date of the notification)"

Held: The notification dated 10.11.2010 served as a policy guideline for the prospective regularization of the contract employees and it did not confer an automatic or retrospective right to regularization

Rather, each case required evaluation based on specific criteria, including performance and the fulfillment of prescribed qualifications

The notification did not stipulate that regularization would be effective from the date of initial contract appointment or from the date of the notification

Instead, it provided a framework for considering the contract employees for regularization

Only upon regularization, the contract employees would enter the regular service stream anew, without retrospective benefits

Contractual employees enjoyed no vested right to regularization much less to be regularized from any particular date

The benefit of regularization extended to them under the regularization policy was prospective in nature and there was no legal justification to give it retrospective application

Any such step would have totally negated the purpose and significance of the contract appointment policy by leaving no distinction between a contractual and a regular employee

Regularization in service was to be treated as a fresh appointment to maintain the integrity of the civil service system and to protect the rights of the existing civil servants

Both regular and contractual employees were governed by two separate and distinct legal frameworks

Contractual appointments were governed by specific terms and conditions distinct from those applicable to the regular civil servants

Therefore, allowing the contract employees to claim seniority from the date of notification would have infringed upon the rights of existing regular civil servants, disrupting established hierarchies and entitlements

Therefore, date of regularization could not be the date of the regularization policy envisaged under the notification (i.e. 10.11.2010)

Present as well as connected petition being devoid of any merit, were dismissed, in circumstances.

2024 PLC(CS) 1167 LAHORE-HIGH-COURT-LAHORE Judicial Precedent
Project postsContract employeesConversion from development side to non-development sideNo right of regularization in servicePolicy matterJudicial reviewScope

Rights of the petitioners had already been safeguarded in lieu of a uniform policy by way of giving them extra marks for their services rendered during the currency of projects

Safeguards were in place for the benefit of the project employees including the petitioners, which was essentially a policy matter falling within the domain of the executive

High Court in exercise of judicial review could not navigate beyond and above the policy set out by the executive limb of the State, for project employees, as this would surely amount to the judicial overreach, therefore, a direction could not be passed to the respondents for regularization of service of the petitioners, as of right, without advertising the posts for general public

Any organization aims at continuity in its working and functions which may run into difficulty if the serving employees are ousted from the service and asked to compete in the process

Petitioners, who were admittedly in service, were allowed to continue to work till the completion of the process of recruitment, on regular basis, through competitive process and further continuation of the petitioners would be determined only if they qualify and stand on the merit list

Constitutional petition was disposed of accordingly.

2022 SCMR 406 SUPREME-COURT Judicial Precedent
Contract employeesRegularization in serviceContractual employees had no vested right of regularizationRegularization cannot take place without statutory backing

In the absence of any law, policy or rules, an employee could not knock the door of the Court for regularization of his/her services.

2022 PLC(CS) 1225 SUPREME-COURT Judicial Precedent
Contract employeesRegularization in serviceContractual employees had no vested right of regularizationRegularization cannot take place without statutory backing

In the absence of any law, policy or rules, an employee could not knock the door of the Court for regularization of his/her services.

2022 PLC(CS) 424 SUPREME-COURT Judicial Precedent
Contract employees

Such employees had no vested right to claim regularization.

2021 SCMR 609 SUPREME-COURT Judicial Precedent
Contract employees

Such employees had no vested right to claim regularization.

2021 SCMR 494 SUPREME-COURT Judicial Precedent
S. 3Contract employeesReinstatement and regularization in serviceRespondents were contract employees of a Shrine ("the Shrine") and a Library ("the Library")Both the Shrine and the Library were subsequently handed over to the Provincial Archives and Libraries Department

As a result of this conversion, posts occupied by the respondents were sanctioned by the Provincial Finance Department with the direction to fill the same by fresh recruitment

Respondents were not regularized in the said sanctioned posts

Held, that the Shrine and the Library were subsequently handed over to the administrative control of the Provincial Archives and Libraries Department and thus posts in the Shrine and the Library stood converted to the regular side and the requisite notification was issued by the concerned department which still held the field

Respondents were given assurances that they would be adjusted against the said posts

Respondents had already been declared as civil servants vide an office order

Vide an office memo it was stated that the employees of the Shrine had been appointed as per the prescribed rules and procedure, therefore, they should be adjusted against the posts that were sanctioned

Respondents had been unlawfully relieved because plausible reasons were not given for doing the same

In the absence of such reasons, and by omitting to follow the correct procedure to relieve a civil servant, the Provincial authorities had committed an illegality

Section 3 of the Khyber Pakhtunkhwa Employees (Regularization of Services) Act, 2009 ('the 2009 Act') provided that all contractual or ad hoc employees who had been appointed before the promulgation of the 2009 Act would be deemed to have been validly appointed against regular posts

As such, the Provincial authorities could not circumvent the law and take a different position which was neither supported by the law, nor by the record of its own actions

High Court had rightly re-instated and regularized the services of the respondents

Appeals were dismissed.

2021 PLC(CS) 125 SUPREME-COURT Judicial Precedent
Art. 199Master and servant, relationshipContract employeesConstitutional petition filed by contractual employees seeking regularization in serviceMaintainability

Contractual employees, who were governed by the principle of master and servant, did not have the right to approach the High Court (in its constitutional jurisdiction) to seek redressal of their grievances relating to regularization.

2021 PLC(CS) 125 SUPREME-COURT Judicial Precedent
Contract employeesRegularization in serviceScope

Contractual employees had no automatic right to be regularized unless the same had specifically been provided for in law.

2020 SCMR 2068 SUPREME-COURT Judicial Precedent
Contract employeesRegularization in serviceScope

Contractual employees had no automatic right to be regularized unless the same had specifically been provided for in law.

2020 SCMR 2068 SUPREME-COURT Judicial Precedent
Art. 199Master and servant, relationshipContract employeesConstitutional petition filed by contractual employees seeking regularization in serviceMaintainability

Contractual employees, who were governed by the principle of master and servant, did not have the right to approach the High Court (in its constitutional jurisdiction) to seek redressal of their grievances relating to regularization.

2019 PLC(CS) 928 SUPREME-COURT Judicial Precedent
Contract employee

Contract employee could not press for reinstatement to serve for the left-over period and could at the best claim damages to the extent of unexpired period of his service.

2019 PLC(CS) 681 LAHORE-HIGH-COURT-LAHORE Judicial Precedent
Contract employeesRegularization of serviceAgreement as to non-regularization of contract employmentEffectDiscrimination

Employees filed constitutional petition for regularization of services which was accepted by the Single Judge of High Court with the direction to the department to constitute a committee to consider their case for regularization

Validity

Government had issued a letter whereby autonomous bodies were directed to make appointment on regular basis of the contract appointees in BS-1 to 15

Employers being autonomous body were required to comply with the said letter but they remained failed

High Court observed that agreement that contract appointment did not confer any right of regularization was an obstructive tool in the way of regularization of service of employees

Contract employees could not be deprived from their legal right of regularization in any way when a policy of regularization had been framed by the Government

Employee at the time of appointment on contract while signing the agreement had no position of bargaining with the employer and employer could coerce them to waive their legal protection and accept, contractual terms or face the risk of losing the jobs

Department was bound to implement the policy of Government with regard to regularization of contract employees

Employees were still working in department but employers had deprived them from their legal right

Departments could not be allowed to follow the policy of pick and choose rather they were bound to treat all employees equally qua their service as well as their benefits

Employers were to deal with the employees fairly, justly and honestly qua the matter of regularization of service

Employees were to be treated in accordance with law without any discrimination

In the present case posts against which employees had been appointed were of permanent nature

Employees had been discharging their duties entirely to the satisfaction of employers

Retaining services of employees on the contract instead of on permanent basis was mala fide and unfair

Employees had now become overage for further appointment

No one should be prevented from earning his livelihood

Employees were entitled for regularization of services in circumstances

Competent authority had not applied its mind while exercising its discretion to the grievance of employees rather it had resulted in pick and choose in the exercise of discretion

Intra-court appeal was dismissed in circumstances.

2018 SCMR 1120 SUPREME-COURT Judicial Precedent
R. 23Power of Chief Minister to relax rules in case of hardshipScopeContract employeesRegularization in service

Petitioners were appointed on contract basis for a period of three years, however, only after a year an order was issued by which the petitioners were regularized with immediate effect, in relaxation of the provisions of the Contract Appointment Policy and the Punjab Civil Servants (Appointment and Conditions of Service) Rules, 1974 as a special one-time dispensation

Legality

Rule 23 of the Punjab Civil Servants (Appointment and Conditions of Service) Rules, 1974 ("the Rules") stated that "any of the rules" in "any individual case of hardship" and "for special reasons to be recorded in writing" and "to the extent prescribed" by the Chief Minister may be relaxed

In case of petitioners not a single one of said stipulated preconditions were even mentioned, let alone fulfilled, and were flouted

Reason given by the Principal Secretary to the Chief Minister for relaxing the Contract Appointment Policy and the Rules was to prevent the petitioners from getting better salaries and perks in the private sector and therefore it was deemed to be in the "public interest" to get them regularized

Same Principal Secretary however contradicted himself subsequently and mentioned "compassionate circumstances of the case and the experience accumulated by them [petitioners] during the period of their contractual appointment" as reasons for relaxing the Rules and recommending the petitioners' regularization

Incongruous order was passed which both relaxed the Rules and regularized the petitioners

Such order did not mention the individual hardship of any petitioner, it was not passed by the Chief Minister, "special reasons" were not recorded in writing by the Chief Minister necessitating relaxing of the Rules and the particular rule, i.e. "any one of the rules" was not mentioned

Completely illegal exercise was carried out in purported exercise of R. 23 of the Rules

Principal Secretary to the Chief Minister, implemented the wish of the Chief Minister and did so by resorting to absurd reasons without compunction, and he apparently did so in his enthusiasm to appease and serve the person of the Chief Minister, and not the Province and its people

Supreme Court observed that bureaucrats must remember that they were servants of the State and the people and that their abject subservience to one person (the Chief Minister in the present case) destroyed the confidence of the people in the bureaucracy

Petition for leave to appeal was dismissed accordingly and leave was refused.

2018 PLC(CS) 1217 SUPREME-COURT Judicial Precedent
R. 23Power of Chief Minister to relax rules in case of hardshipScopeContract employeesRegularization in service

Petitioners were appointed on contract basis for a period of three years, however, only after a year an order was issued by which the petitioners were regularized with immediate effect, in relaxation of the provisions of the Contract Appointment Policy and the Punjab Civil Servants (Appointment and Conditions of Service) Rules, 1974 as a special one-time dispensation

Legality

Rule 23 of the Punjab Civil Servants (Appointment and Conditions of Service) Rules, 1974 ("the Rules") stated that "any of the rules" in "any individual case of hardship" and "for special reasons to be recorded in writing" and "to the extent prescribed" by the Chief Minister may be relaxed

In case of petitioners not a single one of said stipulated preconditions were even mentioned, let alone fulfilled, and were flouted

Reason given by the Principal Secretary to the Chief Minister for relaxing the Contract Appointment Policy and the Rules was to prevent the petitioners from getting better salaries and perks in the private sector and therefore it was deemed to be in the "public interest" to get them regularized

Same Principal Secretary however contradicted himself subsequently and mentioned "compassionate circumstances of the case and the experience accumulated by them [petitioners] during the period of their contractual appointment" as reasons for relaxing the Rules and recommending the petitioners' regularization

Incongruous order was passed which both relaxed the Rules and regularized the petitioners

Such order did not mention the individual hardship of any petitioner, it was not passed by the Chief Minister, "special reasons" were not recorded in writing by the Chief Minister necessitating relaxing of the Rules and the particular rule, i.e. "any one of the rules" was not mentioned

Completely illegal exercise was carried out in purported exercise of R. 23 of the Rules

Principal Secretary to the Chief Minister, implemented the wish of the Chief Minister and did so by resorting to absurd reasons without compunction, and he apparently did so in his enthusiasm to appease and serve the person of the Chief Minister, and not the Province and its people

Supreme Court observed that bureaucrats must remember that they were servants of the State and the people and that their abject subservience to one person (the Chief Minister in the present case) destroyed the confidence of the people in the bureaucracy

Petition for leave to appeal was dismissed accordingly and leave was refused.

2018 PLC(CS)N 132 PESHAWAR-HIGH-COURT Judicial Precedent
Rr. 13, 18, 19, 20, 21, 22, 30 & 31Constitution of Pakistan, Art.25Workers Welfare BoardContract employeesRegularization of serviceEqual treatmentScopeEducational qualification and experience of petitioners not disputedIf anyone was not qualified for the post, he could be removed from service by issuing show-cause noticePetitioners were appointed on contract basis after proper advertisementAgreement with regard to regularization was executed between the petitioners and elected representativeRecommendation for regularization of all contract employees was made by the Secretary Workers' Welfare BoardColleagues placed in similar situation had been regularized and discrimination had been done to the petitionersPetitioners were performing their duties and claiming their regularization on sanctioned postsDepartment reserved the right to apply formula of retrenchment as and when required

Employer had prerogative to issue show-cause notice to any of its employees if found deficient on the requisite qualification

Petitioners were serving the department since 2009 and there was no complaint whatsoever with regard to performance, efficiency and conduct of employees

Employees deserved for regularization against the post which they were holding

Claim of employees who fell within the promotion zone be placed before the competent authority for a decision

If any illegality/irregularity had been committed by the employer then employees could not be made scapegoat

Employees had become overage and could not seek employment elsewhere

Petitioners could not be kept for indefinite period on contract

Right of employment was the right of livelihood

High Court observed that petitioners who were in service stood regularized and those who were restrained/dispensed with but appointed on contractual basis stood reinstated

Constitutional petition was allowed accordingly.

2018 PLC(CS)N 22 PESHAWAR-HIGH-COURT Judicial Precedent
PreambleWorkers Welfare BoardContract employeesTermination without following procedure for removal from serviceIrregular appointmentsEffectLocus poenitentiae, principle ofApplicabilityBack benefitsApprobate and reprobateAuthorities terminated services of contract employees without issuing any show-cause notice and conducting of inquiryValidityEmployees were appointed observing the prescribed manner

When someone was appointed after fulfilling required criteria and appointment was made in prescribed manner then service of such employee could only be terminated after following the law governing procedure for removal from service

If said procedure was not followed, termination order would be ultra vires, ab initio void, in violation of law and without lawful authority

No one could be condemned unheard

No reason had been given for termination orders

When an employee had assumed the charge and performed his duties then he could not be terminated without assigning valid reasons after fulfilling procedure prescribed under the rules

Termination during probationary period was not tenable

Persons who had been appointed allegedly without following the rules or on irregular basis could not be penalized

Appointing authority in such circumstances was to proceed against the officials who were responsible, and not the appointees who had served the department for a long period of time

Statutory bodies were to act in accordance with law

In the present case, contract of employees had been extended and their services had been regularized

Once competent authority had regularized service of employee it created valuable right in favour of that employee which could not be reversed by taking contradictory stances at different times

Appointing department could not approbate and reprobate in the same breath with regard to the same matter

Termination orders passed by the department were in violation of rules envisaged in Workers' Welfare Fund (Employees Service) Rules, 1997

If rules and laws were not followed then termination order would be without lawful authority and constitutional petition would be maintainable

Impugned orders were set aside

Employees were directed to be deemed in service from the date of judgment

No salaries would be paid to the employees as they had not served the department

Constitutional petition was allowed in circumstances.

2018 PLC(CS) 580 LAHORE-HIGH-COURT-LAHORE Judicial Precedent
Ss. 5, 8 & 13Punjab Education Foundation (Contract Appointment) Rules, 2006, Rr.5, 6(2) (a) (b) (d) (h) & 9Punjab Education Foundation Service Regulations, 2006, Regln. 5Punjab Education Foundation Employees Service Regulations (Amendment), 2010, Regln.7Contract employeesTermination from serviceRight of hearingPowers of Managing Director of Education FoundationBoard of Director of Education Foundation

Contention of petitioners-employees was that letters for termination of their services were illegal and their service should be regularized

Validity

Executive and managing authority of the Education Foundation was with its Board of Directors

Board of Directors had powers to appoint employees and other functionaries of the Education Foundation and determine the terms and conditions of their employment

Managing Director of the Education Foundation could exercise all such powers and could do all such acts and things as were authorized by Board of Directors

Contractual appointments were made on the basis of merits which did not confer any right for regular appointment

Managing Director had powers to terminate the services of contract employees without assigning any reason or without approval of Board of Directors or Provincial Government

Managing Director could only extend the contract and re-negotiate new terms and conditions of contractual appointment with the approval of Board of Directors

Provincial Government had powers to make rules for carrying out the purposes of Punjab Education Foundation Act, 2004 through notification

Provincial Government had allowed the Education Foundation to engage personnels on contract basis

Punjab Education Foundation (Contract Appointment) Rules, 2006 having been sanctioned by the Provincial Government were applicable to the employees and Education Foundation

Punjab Education Foundation (Contract Appointment) Rules, 2006 had statutory status and deviation from the same could be enforced by competent Court

Petitioners being employees of Education Foundation had accepted employment on the basis of their service contract and agreed to be governed by Punjab Education Foundation (Contract Appointment) Rules, 2006, thus were governed by Punjab Education Foundation (Contract Appointment) Rules, 2006 having statutory backing

Managing Director of the Foundation could terminate the services of contract employees on one month's salary in lieu of terms and condition of contract appointment

Impugned letters were issued in compliance with the directions of the Managing Director of the Foundation

No violation of contract employment or statutory Rules i.e. Punjab Education Foundation (Contract Appointment) Rules, 2006 had been made by the Education Foundation

Employees enjoyed extension in their contract through letters none of which were signed by Managing Director but Human Resource Department which was not the appointing Authority

Employees did not raise any objection for such matter and only raised the objections in case of their termination

Termination of service had been approved by the Chief Minister

Education Foundation had to evaluate as to who was the employee worthy of serving the best interest of Foundation and as to who was more suitable

Impugned decision for not extending the contracts by the Education Foundation had been made pursuant to deliberations and approval of Managing Director and Chief Minister

Question of arbitrariness or illegality had no relevance to the matter in circumstances

No statutory rules or provision of Act had been violated by the Education Foundation while terminating the employment of petitioners

Appointment of employees was temporary on contract basis which could be terminated in absence of any violation of provision of law/statutory rules

Employees were entitled to one month's notice or salary in lieu of terms and conditions of contract

Petitioners-employees had failed to point out any contravention of their Fundamental Right by the Education Foundation

Such decision could not be interfered by the High Court in its constitutional jurisdiction

Services governed by a contract would not confer a guaranteed right on the employee to continue in employment and to seek reinstatement on being illegally dismissed or terminated

Such employees could not approach Court of law for seeking appointment even if they were refused employment illegally or in contravention of service contract or non-statutory rules/regulations

Damages against such termination under principle of "master and servant" could be claimed

Contract of employees had expired before impugned letters

Constitutional petition could not be allowed conferring such right to the petitioners

No statutory provision existed for regular appointment of petitioners in the Education Foundation

Directions of Chief Minister could not have precedence over the Punjab Education Foundation (Contract Appointment) Rules, 2006

Education Foundation had not raised any allegation on the employees therefore right of hearing was not mandatory to be provided

Constitutional petition was dismissed in circumstances.

2018 PLC(CS) 619 ISLAMABAD Judicial Precedent
S. 5Civil Servants (Appointment, Promotion and Transfer) Rules, 1973, Pt. IIIContract employeesRegularization in servicePolicy issued by the Federal Government to regularize contract employees (Regularization policy)ScopeRegularization policy could not be inconsistent with primary legislation, such as the Civil Servants Act, 1973

Federal Government was not empowered to bypass or render statutory provisions redundant by way of a regularization policy

Likewise, a delegated legislation, such as the Civil Servants (Appointment, Promotion and Transfer) Rules, 1973 would prevail to the extent of conflict with a regularization policy

Policy of the Federal Government had to be interpreted in conformity with the statutory provisions or delegated legislation made there under.

2017 PLC(CS)N 116 PESHAWAR-HIGH-COURT Judicial Precedent
PreambleCivil Servants Act (LXXI of 1973), PreambleKhyber Pakhtunkhwa Universities Act (X of 2012), Ss. 40 & 41Constitution of Pakistan, Art.199Constitutional petitionMaintainabilityCivil serviceContract employeesRegularization of serviceScopePetitioners-employees were serving the University in the capacity of contract/fixed paid employees

University was a creation of Statute and its Syndicate/Senate had been empowered to formulate its rules/statutes to be approved by the Chancellor (Governor of the Province)

University, thus was a statutory body

Petitioners could not be held as civil servants for the purpose of Khyber Pakhtunkhwa Service Tribunals Act, 1974

Employees had rightly approached the High Court in its constitutional jurisdiction and constitutional petition was maintainable

Authorities instead of making appointments on regular basis appointed petitioners on contract/fixed pay basis or ad hoc basis and kept them in same status

Employees possessed prescribed qualification for the post held by them and had sufficient experience besides no objection was on record about their performance

Similarly placed employees having been regularized petitioners could not be allowed to be discriminated

Employees had been adjusted on sanctioned budgetary posts, they had a right to be regularized on said regular posts

One day artificial break was given in every order while extending the contract services of employees to deprive them of regularization of their service

Authorities were directed by the High Court to regularize the services of petitioners-employees within thirty days

Employees would not be entitled to back benefits

Constitutional petitions were allowed in circumstances.

2016 PLC(CS) 575 PESHAWAR-HIGH-COURT Judicial Precedent
Contract employeesTermination of serviceScopeDiscriminationPetitioners were holding civil posts in connection with the affairs of the Federation and were civil servantsTerms and conditions of service of petitioners were to be regulated by Khyber Pakhtunkhwa Civil Servants Act, 1973

Matters falling within the domain of Art.240 of the Constitution and Khyber Pakhtunkhwa Civil Servants Act, 1973 would not be out of the ambit of a Constitutional court

Procedure for the purpose of appointment was followed properly and selection of petitioners were made by the competent selection committees

All the appointments were temporary on contract basis for fixed terms or till arrival of recommendations of Public Service Commission

Petitioners took-over the charge under the settled law of the land

All the posts were converted into regular with creation of regular posts

Petitioners were continuously in-service right from the day of appointments till the issuance of impugned dispensation order

Even dispensed with/terminated employees had been re-appointed by reducing the upper age limit against the regular posts

Appointments had been made on regular basis from amongst the dispensed with employees

Petitioners had been discriminated who had become over-aged by now

Constitutional petition was accepted in circumstances.

2016 PLC(CS) 966 LAHORE-HIGH-COURT-LAHORE Judicial Precedent
S. 15Notification No. DS (O&M)5-3/2004/CONTRACT(MF) dated 14-10-2009Civil serviceContract employeesRegularization ofScope

Earlier constitutional petition filed by the petitioners-employees was accepted and matter was remitted to the Provincial Chief Secretary for redressal of petitioners' grievance

Chief Secretary refused to regularize the services of petitioners-employees

Contention of Government was that the posts of petitioners were contractual and not permanent

Validity

Petitioners were contract employees who were offered contract of service 9 to 11 years ago through an open competition after due process of law

Government had extended contract of petitioners without break of single day

All assets and liabilities of irrigation and drainage system had been transferred to the Authority

Petitioners-employees were performing their duties from the last more than 10 to 11 years and notification dated 14-10-2009 for regularization of services was applicable to their case

If authorities were aggrieved of the findings recorded in the previous constitutional petition that the regularization notification was applicable to the petitioners, they should have assailed the same according to law

Authorities had failed to point out that petitioners were appointed on a project

Act of authorities to terminate services of petitioners by declaring them as contract employees was against the "fundamental right of life"

Government was directed by High Court to regularize the petitioners' services in terms of regularization Notification No.DS(O&M)5-3/ 2004/CONTRACT(MF) dated 14-10-2009

Constitutional petition was allowed in circumstances.

2016 PLC(CS) 936 ISLAMABAD Judicial Precedent
S. 2(2)Contract employeesRegularization of serviceDecision by Cabinet Committee

Petitioners were recruited in BPS-16 who assailed regularization of service of respondents on the ground that respondents were contract employees and competent authority to appoint them was Federal Public Service Commission

Validity Respondents were working on contract basis and their contract period was extended further which was not challenged at any time by petitioners

Regularization of contract employees, who were appointed on contract basis for a certain period was not supposed to put to tests by Federal Public Service Commission

Decision was passed by Cabinet Sub-Committee for regularization of service of contract/daily wages employees in ministries/divisions/attached departments/ autonomous bodies/organizations etc.

Recommendations of Cabinet Sub-Committee were binding upon all ministries/divisions/attached departments/autonomous bodies/organizations etc. as a policy decision of government, therefore, final order with regard to regularization of service had to be issued by concerned authority inside department in view of S.2(2) of Civil Servants Act, 1973, which was derived basically from Estacode the service structure including almost all types of services in Pakistan

High Court declined to interfere in order passed by the authorities

Petition was dismissed in circumstances.

2016 PLC(CS) 642 ISLAMABAD Judicial Precedent
Contract employeesWithholding of salaries

Grievance of petitioners was that authorities withheld their salaries on the pretext that Planning Commission of Pakistan had not released the same

Validity

Petitioners kept on performing their duties after extension of their contracts which were extended by a state owned Corporation

If the Corporation had not consulted Government, petitioners should not suffer

Federal Government could proceed against persons at the helm of affairs of the corporation and concerned Ministry for alleged violation of directions of Prime Minister

Government was to issue funds from Public Sector Development Project and it was withholding the same without lawful justification

Petitioners were full time workers and they were entitled to withdraw their salaries and consequential benefits

Withholding of such benefits amounted to violation of fundamental rights of petitioners

High Court directed the authorities to release funds for payment of salaries to petitioners

Constitutional petition was allowed accordingly.

2014 PLC(CS) 1 LAHORE-HIGH-COURT-LAHORE Judicial Precedent
Arts. 4 & 25Civil serviceTermination ofContract employeesScope

Such employees would be entitled to be treated fairly in terms of Arts.4 & 25 of the Constitution.

2014 PLC(CS) 1153 KARACHI-HIGH-COURT-SINDH Judicial Precedent
Ss. 2(b), 2(d), 2(e) & 3Constitution of Pakistan, Arts.3, 4, 25, 38 & 199Constitutional petitionContract employeesRegularization of serviceObject and Scope of Sindh (Regularization of Ad Hoc and Contract Employees) Act, 2013ExploitationDiscriminationEligibility and suitability of the petitioners was not questioned

Contention of the petitioners was that they were made a subject of discrimination, as summary for regularization of their services of other similarly circumstanced employees of Health Department had been forwarded, but the petitioners were left out despite the fact that during the pendency of the Constitutional Petition on 25th March, 2013, Sindh (Regularization of Ad hoc and Contract Employees) Act, 2013 had been promulgated

Regularization of project post and exclusion of employees on daily-wages and work-charged basis

Scope

Employee who had been appointed on ad hoc and contract basis against the post in BS-1 to BS-18 or equivalent basic scales, who were otherwise eligible for appointment on such post and was in service in the Government department and its project in connection with the affairs of the Province, immediately before the commencement of said Act, shall be deemed to have been validly appointed on regular basis

Said Act excluded the employees appointed on daily-wages and work-charged basis from its purview

After promulgation of said Act, there was no interference or hindrance for regularization of employees who were performing their duties on ad hoc or contract basis and any denial to such right to any employee who was otherwise eligible under the said Act would be deemed to be exploitation

Under Art.3 of the Constitution, it was the responsibility of the State to ensure elimination of all forms of exploitation and gradual fulfillment of the fundamental principle, from each according to his ability, to each according to his work

Government was responsible to apply and allow the benefit to all employees placed in equal and similar circumstances without any discrimination and not to pick and choose the employee for conferring the benefit or advantage

When the law giver had declared or promulgated any beneficial law, it was his responsibility to implement it across the board with an open heart and benevolence without any conservative or rigid approach

Said Act was a beneficial statute proclaimed with the sole aim to provide and secure the rights of a particular category or class of employees for their betterment and to safeguard and preserve the contractual or ad hoc employment into a permanency

Said Act enshrined that the efforts should be made to bequeath the benefit and its advantage to all the deserving employees in rem rather than to seek ways and means to deprive them on one or the other pretext which was against the norms of good governance

Constitutional petition was disposed of with directions to the authorities.

2013 SCMR 304 SUPREME-COURT Judicial Precedent
Contract employeesRegular appointment, right ofScope

Contract employees did not have a vested right for regular appointment.

2013 SCMR 304 SUPREME-COURT Judicial Precedent
Ss. 8(c)(iii), 12(1) & 16(3)(a)Khyber Pakhtunkhwa Zakat and Ushr Act (XVII of 2011), S. 8(c)(ii)Sindh Zakat and Ushr Act (X of 2011), S. 8(c)(ii)Balochistan Zakat and Ushr Ordinance (I of 2011), S.8(c)(ii)Constitution of Pakistan, Art. 184(3)

Matter regarding regularization of contract employees of Zakat Department as well as appointment of Chairman of Central Zakat Council

Contract employees

Regular appointment, right of

Scope

Petitioners were employed on contractual basis for fixed terms by their respective District Zakat Committees and were paid emoluments out of the Zakat Fund set up under the Zakat and Ushr Ordinance, 1980

Petitioners sought regularization of their services at par with other regular employees of Zakat and Ushr Department

Contentions of petitioners were that they had been serving the Zakat and Ushr Department for periods ranging from 10 to 17 years; that they were not employees of a project mandated to be wound up upon its completion but were employed in a permanent department of the Government, and that they were performing functions similar to those of regular employees

Validity

Petitioners were employed/recruited on contractual basis by the Chairman of the District Zakat Committees on fixed salaries for specific terms, which were extended from time to time

Petitioners were not appointed against any particular post and their appointment was not made by any government official or authority

Appointment of petitioners was not under a particular law but under a policy decision taken the Central Zakat Committee

Nature of petitioners' employment was for a specific purpose/task and on such score they had no vested right for regular appointment

After the 18th Amendment in the Constitution subject of Zakat and Ushr was devolved to the provinces, however system of collection and disbursement of Zakat remained unchanged notwithstanding such devolution

Before devolution of subject of Zakat and Ushr to Provinces, petitioners were paid their salaries from the Zakat Fund under S.8(c)(iii) of Zakat and Ushr Ordinance, 1980, and even after devolution of the subject to the Provinces, provisions similar to said section were incorporated in enactments made by the Provinces, i.e., Khyber Pakhtunkhwa Zakat and Ushr Act, 2011, Sindh Zakat and Ushr Act, 2011 and Balochistan Zakat and Ushr Act, 2012

Status of petitioners thus remained unchanged even after devolution of the subject of Zakat and Ushr to the Provinces

Petition was dismissed accordingly.

2013 PLC(CS) 1115 SUPREME-COURT Judicial Precedent
Contract employeesRegular appointment, right ofScope

Contract employees did not have a vested right for regular appointment.

2013 PLC(CS) 1115 SUPREME-COURT Judicial Precedent
Ss. 8(c)(iii), 12(1) & 16(3)(a)Khyber Pakhtunkhwa Zakat and Ushr Act (XVII of 2011), S. 8(c)(ii)Sindh Zakat and Ushr Act (X of 2011), S. 8(c)(ii)Balochistan Zakat and Ushr Ordinance (I of 2011), S.8(c)(ii)Constitution of Pakistan, Art. 184(3)

Matter regarding regularization of contract employees of Zakat Department as well as appointment of Chairman of Central Zakat Council

Contract employees

Regular appointment, right of

Scope

Petitioners were employed on contractual basis for fixed terms by their respective District Zakat Committees and were paid emoluments out of the Zakat Fund set up under the Zakat and Ushr Ordinance, 1980

Petitioners sought regularization of their services at par with other regular employees of Zakat and Ushr Department

Contentions of petitioners were that they had been serving the Zakat and Ushr Department for periods ranging from 10 to 17 years; that they were not employees of a project mandated to be wound up upon its completion but were employed in a permanent department of the Government, and that they were performing functions similar to those of regular employees

Validity

Petitioners were employed/recruited on contract basis by the Chairman of the District Zakat Committees on fixed salaries for specific terms, which were extended from time to time

Petitioners were not appointed against any particular post and their appointment was not made by any government official or authority

Appointment of petitioners was not under a particular law but under a policy decision taken by the Central Zakat Committee

Nature of petitioners' employment was for a specific purpose/task and on such score they had no vested right for regular appointment

After the 18th Amendment in the Constitution subject of Zakat and Ushr was devolved to the provinces, however system of collection and disbursement of Zakat remained unchanged notwithstanding such devolution

Before devolution of subject of Zakat and Ushr to Provinces, petitioners were paid their salaries from the Zakat Fund under S.8(c)(iii) of Zakat and Ushr Ordinance, 1980, and even after devolution of the subject to the Provinces, provisions similar to said section were incorporated in enactments made by the Provinces, i.e., Khyber Pakhtunkhwa Zakat and Ushr Act, 2011, Sindh Zakat and Ushr Act, 2011 and Balochistan Zakat and Ushr Act, 2012

Status of petitioners thus remained unchanged even after devolution of the subject of Zakat and Ushr to the Provinces

Petition was dismissed accordingly.

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