Legal Document View

Unlock Advanced Research with PRISMAI

- Know your Kanoon - Doc Gen Hub - Counter Argument - Case Predict AI - Talk with IK Doc - ...
Upgrade to Premium
[Cites 6, Cited by 0]

Chattisgarh High Court

Akhilesh Kumar Singh vs State Of Chhattisgarh on 12 March, 2026

YOGESH Digitally signed by
       YOGESH TIWARI

TIWARI 17:42:41 +0530
       Date: 2026.03.17




                                                                     1




                                                                                  2026:CGHC:11985
                                                                                                       NAFR

                                       HIGH COURT OF CHHATTISGARH AT BILASPUR

                                                       WPS No. 504 of 2023
                             Akhilesh Kumar Singh S/o Tikeshwar Singh Aged About 32 Years
                             Presently Posted As Assistant Programmer At MGNREGA, Janpad
                             Panchayat Udaipur, District Surguja (C.G.), R/o Village Bhalu Kachhar,
                             Post   Bargawan,     Police   Station       -   Darima,   District    -   Surguja,
                             Chhattisgarh.
                                                                                                  ... Petitioner
                                                               versus
                             1 - State of Chhattisgarh Through Secretary, Department of Panchayat
                             And Rural Development Mahanadi Bhawan, New Raipur, District :
                             Raipur, Chhattisgarh
                             2 - Director, Directorate of Panchayat, Indrawati Bhawan, New Raipur,
                             District : Raipur, Chhattisgarh
                             3 - Commissioner, Mahatma Gandi National Rural Employment
                             Guarantee Act, Indrawati Bhawan, New Raipur, District : Raipur,
                             Chhattisgarh
                             4 - Collector/ District Program Coordinator (MGNREGA) Ambikapur,
                             District Surguja, Chhattisgarh.
                             5 - Chief Executive Officer, Zila Panchayat, District Surguja,
                             Chhattisgarh.
                             6 - Chief Executive Officer, Janpad Panchayat Udaypur, District -
                             Surguja, Chhattisgarh.
                             7 - Program Officer MGNREGA, Janpad Panchayat Udaypur, District
                             Surguja, Chhattisgarh.
                                                                                           ... Respondents
                                        (Cause-title taken from Case Information System)
                                       2

For Petitioner              : Mr. Kishore Narayan and Mr. Sourabh
                              Pandey, Advocates
For Respondents No.1        : Ms. Akanksha Verma Dabhadker, Panel
and 2/State                   Lawyer
For Respondents No.4 to : Mr. Sudeep Verma, Advocate
7


             Hon'ble Shri Amitendra Kishore Prasad, Judge
                              Order on Board
12.03.2026


1.   By way of the present petition, the petitioner assails the order

     dated 07.09.2021 and seeks quashment thereof along with a

     direction to the respondents to reinstate the petitioner with all

     consequential benefits. The petitioner has prayed for following

     relief(s) :-


             "10.1 That the Hon'ble Court may kindly be
             pleased to issue a writ of mandamus setting
             aside the impugned order dated 07.09.2021
             (Annexure P/6), in the interest of justice.

             10.2 That the Hon'ble Court may kindly be
             pleased to issue a writ of mandamus directing
             the respondent to reinstant the petitioner with
             all consequential benefits, in the     interest of
             Justice.

             10.3 Any other relief which this Hon'ble Court
             may    deem    and    proper    in   the   present
             circumstances of the case."

2.   Brief facts of the case, in a nutshell are that, the petitioner was

     appointed to the post of Assistant Programmer on contractual
                                      3

     basis vide order dated 02.11.2016 and was posted at Janpad

     Panchayat Mainpat, District Surguja. His appointment was

     governed by the Chhattisgarh Civil Services (Samvida Niyukti)

     Rules, 2012 (in short "Rules, 2012") for a period of three years

     and, upon satisfactory yearly appraisal of his work, he was

     allowed to continue in service even thereafter. Subsequently, vide

     order dated 06.09.2018, the petitioner was attached to Janpad

     Panchayat Udaipur due to vacancy arising on account of maternity

     leave of the concerned officer, where he joined on 10.09.2018 and

     continued to discharge his duties.


3.   During the course of his service, the petitioner was served with a

     show cause notice dated 19.07.2021 alleging delay in payment of

     wages under MGNAREGA due to improper operation of the

     account in the computer system. The petitioner submitted a reply

     dated 26.07.2021 explaining that the delay occurred because two

     accounts had been opened by the Employment Assistant owing to

     duplicate job cards of certain labourers.


4.   However, without properly considering the petitioner's explanation,

     the respondents passed the impugned order dated 07.09.2021

     discontinuing his services on the ground of adverse remarks in his

     confidential   report.   Thereafter,   the   petitioner   submitted   a

     representation dated 03.03.2022 requesting reinstatement in

     service with an undertaking to improve his work, but no favourable
                                     4

     action was taken, compelling the petitioner to file the present

     petition.


5.   Learned counsel for the petitioner submits that the impugned

     order   dated   07.09.2021     is   wholly   illegal,   arbitrary   and

     unsustainable in law, as the same has been passed in gross

     violation of the principles of natural justice. It is contended that

     before discontinuing the services of the petitioner, no regular

     enquiry was conducted and no effective opportunity of hearing

     was afforded to him. Though certain show-cause notices were

     issued alleging delay in discharge of official duties, the authorities

     proceeded to pass the impugned order without fairly considering

     the reply submitted by the petitioner. He further submits that the

     alleged delay in payment of wages under the MGNREGA scheme

     occurred due to a technical issue relating to duplication of job

     cards and opening of multiple bank accounts of labourers by the

     Employment Assistant. Owing to such discrepancies in the

     accounts provided by the concerned Rojgar Sahayaks, the

     payments to the labourers could not be processed in time. It is

     therefore contended that the alleged lapse cannot be attributed to

     any deliberate negligence or misconduct on the part of the

     petitioner. However, the explanation furnished by the petitioner in

     response to the show-cause notice dated 26.07.2021 was not

     objectively considered by the authority while passing the

     impugned order.
                                     5

6.   It is submitted by learned counsel for the petitioner that the

     impugned order refers to adverse remarks recorded in the

     confidential report/ACR of the petitioner, which allegedly reflected

     his performance as "average". However, the said adverse entry

     was never communicated to the petitioner at any point of time,

     thereby depriving him of an opportunity to submit his explanation

     or representation against such remarks. Learned counsel submits

     that reliance on an uncommunicated adverse entry in the ACR to

     the detriment of the petitioner is legally impermissible and vitiates

     the impugned action. He contends that even though the petitioner

     was appointed on contractual basis as Assistant Programmer

     under the MGNREGA scheme on 02.11.2016 and his contract was

     renewed from time to time, the impugned order entails serious civil

     consequences and therefore adherence to the principles of natural

     justice was mandatory.


7.   Learned counsel lastly submits that even if an employee is

     engaged on contractual basis, the authority cannot resort to

     arbitrary discontinuation of service on the basis of allegations

     relating to misconduct or unsatisfactory performance without

     adhering to the basic safeguards of natural justice. Where the

     termination or discontinuation is founded on allegations which cast

     a stigma or entail adverse civil consequences, the concerned

     employee must be made aware of the material relied upon and

     must be given a meaningful opportunity to submit his explanation.

     It is therefore contended that the impugned action of the
                                       6

     respondents, which relies upon alleged adverse performance and

     other imputations without conducting any enquiry or affording an

     effective opportunity of hearing to the petitioner, stands vitiated in

     law and is liable to be set aside on this ground alone.


8.   Learned State counsel submits that the present petition is

     misconceived insofar as the State of Chhattisgarh is concerned,

     inasmuch as no action of the State authorities is under challenge

     in the instant petition nor any specific relief has been sought

     against them. It is contended that the petitioner's grievance, if any,

     is essentially against respondent No.4 - District Programme

     Coordinator, MNREGA, Ambikapur, who is a separate authority

     competent to defend its action. Therefore, the State submits that

     the petition, so far as it relates to the State, is liable to be

     dismissed.


9.   On the other hand, learned counsel for respondents No.4 to 7

     opposes the submissions of the learned counsel for the petitioner

     and submits that the present petition is wholly misconceived and

     liable to be dismissed. It is contended that the petitioner was

     appointed purely on contractual basis under the provisions of the

     Chhattisgarh Civil Services (Samvida Niyukti) Rules, 2012 and his

     continuation in service was subject to yearly assessment of his

     performance     through    the       Confidential   Report/Performance

     Appraisal Report (PAR). It is submitted that the petitioner cannot

     claim continuation or renewal of his contractual appointment as a
                                     7

      matter of right. He further submits that the performance of the

      petitioner during the relevant period, particularly for the year

      2020-21, was found to be unsatisfactory. It is contended that the

      petitioner was negligent in discharge of his duties under the

      MGNREGA scheme and several show cause notices were issued

      to him from time to time pointing out deficiencies in his work.

      However, despite repeated opportunities, the petitioner failed to

      improve his performance, which ultimately resulted in recording

      adverse remarks in his Confidential Report.


10.   It is further submitted by learned counsel that in view of the poor

      performance of the petitioner and the recommendation made by

      the reporting authority, the competent authority decided not to

      extend the contractual engagement of the petitioner. Accordingly,

      the impugned order dated 07.09.2021 was issued discontinuing

      his services. It is contended that the said action is in accordance

      with the provisions of the Rules, 2012 and the terms and

      conditions of the contractual appointment. He lastly submits that

      since the appointment of the petitioner was purely contractual and

      subject to assessment of his yearly performance, the decision not

      to renew his contract cannot be termed arbitrary or illegal.

      Therefore, the impugned order does not suffer from any illegality

      or infirmity warranting interference by this Court and the present

      petition deserves to be dismissed.
                                        8

11.   By filing a rejoinder-affidavit, learned counsel for the petitioner

      submits that the objection raised by respondents No.4 to 7

      regarding delay and laches is misconceived. It is contended that

      the impugned order dated 07.09.2021 was served upon the

      petitioner belatedly and thereafter the petitioner made several

      efforts   to   approach    the       competent   authorities   seeking

      reconsideration of the order. The petitioner also submitted a

      representation dated 03.03.2022 requesting reinstatement in

      service. However, as no action was taken on the said

      representation and all efforts of the petitioner went in vain, he was

      constrained to file the present writ petition on 12.01.2023. It is

      further submitted that the petitioner belongs to a tribal community

      and is a resident of a backward area of Surguja Division and

      considerable time was consumed in arranging legal assistance,

      collecting documents and arranging resources to approach this

      Court. Thus, the alleged delay is neither deliberate nor intentional

      and stands sufficiently explained.


12.   Learned counsel further submits that the justification put forth by

      the respondents regarding discontinuation of the petitioner's

      services on the basis of adverse remarks in the Confidential

      Report/Performance Appraisal Report for the year 2020-21 is

      wholly untenable. It is contended that the said adverse remarks

      were never communicated to the petitioner and the respondents

      themselves have admitted that the ACR/PAR was not required to

      be communicated to a contractual employee. It is submitted that
                                       9

      non-communication of adverse entries is violative of the principles

      of natural justice and such uncommunicated remarks cannot be

      used to the detriment of the petitioner. It is further contended that

      the show cause notices issued to the petitioner only referred to

      certain technical errors in online entries relating to MGNREGA

      payments and the explanation submitted by the petitioner was not

      objectively considered. Therefore, the ground of poor performance

      reflected in the confidential report appears to be an afterthought

      and the impugned order of termination is arbitrary and

      disproportionate.


13.   Reliance is placed upon the ruling rendered in Mahendra Kumar

      Shrivastava     v.   Chhattisgarh     State     Power       Distribution

      Company Limited & Others, WPS No. 7484 of 2023, decided

      on 02.12.2025 by this Court, wherein it has been held that an

      uncommunicated adverse entry in the ACR cannot be relied upon

      to the detriment of an employee.


14.   Reliance is also placed on the judgment rendered by the Hon'ble

      Supreme Court in Parshotam Lal Dhingra v. Union of India,

      1957 SCC OnLine SC 5 and Swati Priyadarshini v. State of

      Madhya Pradesh, 2024 SCC OnLine SC 2139, wherein the

      Hon'ble   Supreme      Court   reiterated     that   even    contractual

      employees are entitled to the protection of principles of natural

      justice when an adverse action affecting their civil rights is taken.
                                       10

15.   Further reliance is placed on Krishnadutt Awasthy v. State of

      Madhya Pradesh, 2025 LiveLaw (SC) 129, wherein it has been

      held by the Hon'ble Supreme Court that when an administrative

      decision is based upon any report or material adverse to an

      employee, the same must be furnished to him before passing any

      adverse order.


16.   I have heard learned counsel appearing for the parties at length

      and perused the documents annexed with the writ petition.


17.   At the outset, it is not in dispute that the petitioner was engaged

      on contractual basis under the provisions of the Chhattisgarh Civil

      Services (Samvida Niyukti) Rules, 2012 and that his continuation

      was subject to periodic assessment of performance. It is equally

      well settled that a contractual employee does not have an

      indefeasible right to seek renewal or continuation in service.

      However, it is now firmly entrenched in service jurisprudence that

      even in cases of contractual engagement, the State and its

      instrumentalities are bound to act in a fair, reasonable and non-

      arbitrary manner, particularly when the action taken entails civil

      consequences or carries a stigma affecting the reputation and

      future prospects of the employee.


18.   In the present case, though the impugned order dated 07.09.2021

      is couched in the form of discontinuation of contractual service, a

      deeper scrutiny of the record reveals that the same is founded

      upon   allegations   relating        to   unsatisfactory   performance,
                                           11

      negligence in discharge of duties and adverse remarks recorded

      in the Confidential Report/Performance Appraisal Report of the

      petitioner. Thus, the order is not a simpliciter non-renewal of

      contract but is stigmatic in nature, as it attributes deficiencies in

      the conduct and performance of the petitioner.


19.   Once the action of the employer is founded upon allegations which

      cast a stigma or are punitive in nature, the requirement of

      adherence     to   the    principles        of   natural     justice   becomes

      indispensable. In such circumstances, the employer is under an

      obligation to conduct a fair enquiry, disclose the material sought to

      be relied upon and afford an effective opportunity of hearing to the

      concerned employee.


20.   In the case at hand, it is evident that although certain show cause

      notices were issued to the petitioner alleging delay in processing

      payments under the MGNREGA scheme, the explanation

      furnished by the petitioner attributing such delay to duplication of

      job cards and opening of multiple accounts by the concerned

      functionaries has not been objectively considered by the

      respondents. There is nothing on record to indicate that any

      proper enquiry was conducted to ascertain the correctness of the

      explanation or to fix responsibility upon the actual erring officials.


21.   More importantly, the impugned order heavily relies upon adverse

      remarks    recorded      in   the        Confidential      Report/Performance

      Appraisal Report for the year 2020-21. Admittedly, such adverse
                                      12

      entry was never communicated to the petitioner. The stand of the

      respondents that communication of ACR/PAR is not required in the

      case of contractual employees cannot be accepted, as it strikes at

      the very root of fairness in administrative action.


22.   It is a settled principle of law that any adverse entry in the service

      record of an employee, which is sought to be relied upon to his

      detriment, must be communicated to him so as to enable him to

      make an effective representation. Non-communication of such

      adverse remarks renders the action based thereon arbitrary and

      violative of the principles of natural justice. The petitioner, in the

      present case, has been deprived of an opportunity to contest or

      explain the adverse assessment of his performance, which has

      ultimately formed the basis of his discontinuation.


23.   Further, the material on record indicates that the alleged

      deficiencies in performance were, at least in part, attributable to

      systemic or technical issues in the implementation of the

      MGNREGA scheme, particularly relating to duplication of job cards

      and discrepancies in bank accounts of labourers. In the absence

      of any proper enquiry to establish wilful negligence or misconduct

      on the part of the petitioner, fastening such consequences upon

      him appears to be wholly unjustified.


24.   This Court also finds substance in the submission of learned

      counsel for the petitioner that the reliance placed upon

      uncommunicated adverse entries and undisclosed material vitiates
                                       13

      the decision-making process. The law laid down by the Hon'ble

      Supreme Court in the decisions relied upon by the petitioner

      clearly mandates that any material adverse to an employee must

      be disclosed to him before it is used against him and that even a

      contractual employee is entitled to the protection of principles of

      natural justice when an action affecting his civil rights is taken.


25.   In the considered opinion of this Court, the impugned order dated

      07.09.2021 suffers from multiple legal infirmities, namely--(i) it is

      founded upon stigmatic considerations without holding any regular

      enquiry; (ii) it relies upon adverse entries in the Confidential

      Report which were never communicated to the petitioner; (iii) it

      reflects non-application of mind to the explanation furnished by the

      petitioner; and (iv) it is arbitrary and violative of the principles of

      natural justice.


26.   The objection raised by the respondents regarding delay and

      laches also does not merit acceptance. The petitioner has

      sufficiently explained the delay by stating that he had made

      representations before the authorities and, being a resident of a

      remote tribal area, faced practical difficulties in approaching this

      Court. In the facts and circumstances of the case, the delay

      cannot be said to be inordinate or unexplained so as to non-suit

      the petitioner on this ground alone.


27.   This Court also finds support from recent pronouncements of the

      Hon'ble Supreme Court emphasizing that the State, being a model
                                  14

employer, cannot resort to arbitrary discontinuation of long-serving

contractual employees merely on the strength of the contractual

label. In Dharam Singh v. State of U.P., 2025 SCC OnLine SC

1735,   the   Hon'ble       Supreme       Court     deprecated      arbitrary

disengagement     of      long-serving    employees       and      held   that

prolonged ad-hoc or contractual engagement cannot be used as a

device to deny constitutional protections, and any such action

must withstand the test of fairness, non-arbitrariness and

reasonableness under Articles 14, 16 and 21 of the Constitution.

The Hon'ble Supreme Court has held as under :-


        "15. It is manifest that the Appellant Workmen
        continuously rendered their services over
        several years, sometimes spanning more than
        a decade. Even if certain muster rolls were not
        produced in full, the Employer's failure to
        furnish such records- despite directions to do
        so-allows an adverse inference under well-
        established labour jurisprudence. Indian labour
        law strongly disfavors perpetual daily-wage or
        contractual engagements in circumstances
        where the work is permanent in nature. Morally
        and    legally,    workers       who    fulfil   ongoing
        municipal requirements year after year cannot
        be    dismissed      summarily     as     dispensable,
        particularly in the absence of a genuine
        contractor agreement. At this juncture, it would
        be appropriate to recall the broader critique of
        indefinite "temporary" employment practices as
        done by a recent judgment of this court in
                            15

Jaggo v. Union of India, in the following
paragraphs:

  "22. The pervasive misuse of temporary
  employment contracts, as exemplified in this
  case, reflects a broader systemic issue that
  adversely affects workers' rights and job
  security. In the private sector, the rise of the
  gig economy has led to an increase in
  precarious employment arrangements, often
  characterized by lack of benefits, job security,
  and fair treatment. Such practices have been
  criticized     for      exploiting          workers     and
  undermining labour standards. Government
  institutions, entrusted with upholding the
  principles of fairness and justice, bear an
  even greater responsibility to avoid such
  exploitative employment practices. When
  public sector entities engage in misuse of
  temporary contracts, it not only mirrors the
  detrimental trends observed in the gig
  economy        but     also     sets        a   concerning
  precedent that can erode public trust in
  governmental operations.

  .........

25. It is a disconcerting reality that temporary employees, particularly in government institutions, often face multifaceted forms of exploitation. While the foundational purpose of temporary contracts may have been to address short-term or seasonal needs, they have increasingly become a mechanism to evade long-term obligations owed to 16 employees. These practices manifest in several ways:

• Misuse of "Temporary" Labels: Employees engaged for work that is essential, recurring, and integral to the functioning of an institution are often labelled as "temporary" or "contractual," even when their roles mirror those of regular employees. Such misclassification deprives workers of the dignity, security, and benefits that regular employees are entitled to, despite performing identical tasks.
•     Arbitrary          Termination:       Temporary
employees           are        frequently    dismissed
without cause or notice, as seen in the present case. This practice undermines the principles of natural justice and subjects workers to a state of constant insecurity, regardless of the quality or duration of their service.
• Lack of Career Progression: Temporary employees often find themselves excluded from opportunities for skill development, promotions, or incremental pay raises. They remain stagnant in their roles, creating a systemic disparity between them and their regular counterparts, despite their contributions being equally significant.
• Using          Outsourcing         as      a Shield:
Institutions        increasingly            resort     to
outsourcing roles performed by temporary 17 employees, effectively replacing one set of exploited workers with another. This practice not only perpetuates exploitation but also demonstrates a deliberate effort to bypass the obligation to offer regular employment.
• Denial of Basic Rights and Benefits:
Temporary employees are often denied fundamental benefits such as pension, provident fund, health insurance, and paid leave, even when their tenure spans decades. This lack of social security subjects them and their families to undue hardship, especially in cases of illness, retirement, or unforeseen circumstances."
28. Similarly, in Bhola Nath v. State of Jharkhand, 2026 LiveLaw (SC) 95, the Hon'ble Supreme Court reiterated that repeated extensions of contractual engagement coupled with continuous service create a legitimate expectation of fair treatment and that abrupt discontinuation, without adherence to fairness and reasonableness, by observing as under :-
              "Limits      on         Perpetual       Contractual
              Engagements:

13.2. In the present case, the respondent-State had engaged the services of the appellants on sanctioned posts since the year 2012. It was only towards the end of the year 2022 that the respondents communicated that no further extension of the appellants' engagement was likely to be granted.
18

13.3. In our considered opinion, the aforesaid action is not only vitiated by arbitrariness but is also in clear derogation of the equality principles enshrined in Article 14 of the Constitution. The respondent-State initially engaged the appellants in their youth to discharge public duties and functions. Having rendered long and dedicated service, the appellants cannot now be left to fend for themselves, particularly when the employment opportunities that may have been available to them a decade ago are no longer accessible owing to age constraints.

13.4. We are unable to discern any rational basis for the respondent-State's decision to discontinue the appellants after nearly ten years of continuous service. We are conscious that the symbiotic-relationship between the appellants and the respondent-State was mutually beneficial, the State derived the advantage of the appellants' experience and institutional familiarity, while the appellants remained in public service. In such circumstances, any departure from a long- standing practice of renewal, particularly one that frustrates the legitimate expectation of the employees, ought to be supported by cogent reasons recorded in a speaking order.

13.5. Such a decision must necessarily be a conscious and reasoned one. An employee who has satisfactorily discharged his duties over several years and has been granted 19 repeated extensions cannot, overnight, be treated as surplus or undesirable. We are unable to accept the justification advanced by the respondents as the obligation of the State, as a model employer, extends to fair treatment of its employees irrespective of whether their engagement is contractual or regular.

13.6. This Court has, on several occasions, deprecated the practice adopted by States of engaging employees under the nominal labels of "part-time", "contractual" or "temporary" in perpetuity and thereby exploiting them by not regularizing their positions. In Jaggo v. Union of India, 2024 SCC OnLine SC 3826 this Court underscored that government departments must lead by example in ensuring fair and stable employment, and evolved the test of examining whether the duties performed by such temporary employees are integral to the day-to-day functioning of the organization.

13.7. In Shripal v. Nagar Nigam,2025 SCC OnLine SC 221 and Vinod Kumar v. Union of India, (2024) 9 SCC 327 this Court cautioned against a mechanical and blind reliance on Umadevi (supra) to deny regularization to temporary employees in the absence of statutory rules. It was held that Umadevi (supra) cannot be employed as a shield to legitimise exploitative engagements continued for years without undertaking regular recruitment. The Court further clarified that Umadevi itself draws a distinction between 20 appointments that are "illegal" and those that are merely "irregular", the latter being amenable to regularization upon fulfilment of the prescribed conditions.

13.8. In Dharam Singh v. State of U.P. 2025 SCC OnLine SC 1735, this Court strongly deprecated the culture of "ad-hocism" adopted by States in their capacity as employers. The Court criticised the practice of outsourcing or informalizing recruitment as a means to evade regular employment obligations, observing that such measures perpetuate precarious working conditions while circumventing fair and lawful engagement practices.

13.9. The State must remain conscious that part-time employees, such as the appellants, constitute an integral part of the edifice upon which the machinery of the State continues to function. They are not merely ancillary to the system, but form essential components thereof. The equality mandate of our Constitution, therefore, requires that their service be reciprocated in a manner free from arbitrariness, ensuring that decisions of the State affecting the careers and livelihood of such part-time and contractual employees are guided by fairness and reason.

13.10. In the aforesaid backdrop, we are unable to persuade ourselves to accept the respondent-State's contention that the mere contractual nomenclature of the appellants' engagement denudes them of constitutional 21 protection. The State, having availed of the appellants' services on sanctioned posts for over a decade pursuant to a due process of selection and having consistently acknowledged their satisfactory performance, cannot, in the absence of cogent reasons or a speaking decision, abruptly discontinue such engagement by taking refuge behind formal contractual clauses. Such action is manifestly arbitrary,inconsistent with the obligation of the State to act as a model employer, and fails to withstand scrutiny under Article 14 of the Constitution."

29. In light of the aforesaid authoritative pronouncements, the contention of the respondents that the petitioner, being a contractual employee, had no right to continuation and therefore no procedural safeguards were required, cannot be accepted in its absolute form. While it is true that a contractual employee cannot claim renewal as a matter of right, it is equally well settled that where the discontinuation is founded on allegations of unsatisfactory performance or carries a stigma, the employer is bound to follow the principles of natural justice.

30. The judgments relied upon by the respondents to contend that a contractual employee has no vested right to continuation are clearly distinguishable on facts. In those cases, the discontinuation was simpliciter on account of expiry of contractual tenure or administrative exigency, without any imputation of misconduct or adverse performance. In the present case, however, the 22 discontinuation is not a mere non-renewal but is founded upon allegations of negligence and adverse entries in the Confidential Report, which undoubtedly cast a stigma upon the petitioner.

31. Furthermore, in the present case, the impugned action is vitiated by reliance on uncommunicated adverse entries and by failure to afford an effective opportunity of hearing. Such foundational defects were neither present nor under consideration in the judgments relied upon by the respondents. Therefore, the said authorities do not advance the case of the respondents and are clearly inapplicable to the facts of the present case.

32. In view of the foregoing discussion and for the reasons recorded hereinabove, this Court has no hesitation in holding that the impugned order dated 07.09.2021 is vitiated both on facts and in law. The action of the respondents, though ostensibly presented as a mere discontinuation of contractual engagement, is in substance founded upon allegations touching the petitioner's performance and conduct, thereby rendering the same stigmatic in nature. Such an action, which entails serious civil consequences affecting the petitioner's livelihood and future prospects, could not have been taken without strict adherence to the principles of natural justice. The failure of the respondents to conduct any fair or regular enquiry, the non-consideration of the petitioner's explanation in its proper perspective, and most significantly, the reliance upon uncommunicated adverse entries in the Confidential 23 Report/Performance Appraisal Report, collectively demonstrate a clear arbitrariness and non-application of mind in the decision-

making process. The impugned order, therefore, cannot be sustained as it falls foul of the settled legal principles governing administrative fairness and transparency.

33. Accordingly, the order dated 07.09.2021 is hereby quashed and set aside, with all consequential benefits flowing in favour of the petitioner. As a natural corollary, the respondents are directed to reinstate the petitioner to the post on which he was working prior to issuance of the impugned order, with all consequential benefits.

However, it is made clear that the respondents shall be at liberty to take appropriate action in accordance with law, if so advised, by following due process and by affording full opportunity of hearing to the petitioner.

34. The writ petition is accordingly allowed.

35. There shall be no order as to costs.

Sd/-

(Amitendra Kishore Prasad) Judge Yogesh