Seven Years' Service Falls Short: Delhi High Court Holds Temporary Employees Cannot Claim Regularization Under Umadevi Exception Without Completing Ten Years

1. Case Snapshot

Case Name: Keshav Dutt & Ors vs Delhi Tourism & Transport Development Corporation Limited & Anr

Citation: LPA 307/2015

High Court: High Court of Delhi

Bench: Hon'ble Mr. Justice V. Kameswar Rao and Hon'ble Ms. Justice Manmeet Pritam Singh Arora

Date of Judgment: 19th June, 2026

Area of Law: Service Law, Constitutional Law, Regularization of Temporary Employees

2. Judgment in Brief

The Delhi High Court dismissed an intra-court appeal filed by 11 temporary employees who sought regularization of their services with Delhi Tourism & Transport Development Corporation (DTTDC). The appellants were appointed in 2007 on a short-term basis pursuant to an advertisement that expressly stated the employment was for a limited period. Their services were continued through various extensions until 31.12.2014, when they were discontinued. The Court held that the appellants had worked for only seven years and therefore did not meet the ten-year service condition prescribed in paragraph 53 of the landmark Supreme Court judgment in Secretary, State of Karnataka v. Umadevi (3) and Others. The Court clarified that the exception carved out in Umadevi for regularization of irregularly appointed employees is strictly conditional upon completion of ten years or more of continuous service, and employees with lesser service cannot claim the benefit of that exception.

3. Relevant Facts

Appointments of the Appellants

• The appellants (11 individuals) were appointed as helpers/attendants with the Delhi Tourism & Transport Development Corporation (DTTDC), a Government undertaking.

• On 26.06.2007, DTTDC published an advertisement stating that helpers/attendants were required for a short period.

• The appellants were selected pursuant to this advertisement and were issued appointment memoranda that clarified their services were for a period of six months only and would not entitle them to any right or claim of further continuation or regular appointment.

Challenge to Advertisement

• On 05.07.2007, the advertisement was challenged in W.P.(C) No.4766/2007. The Court held that as there was an urgent need for filling up posts on a short-term basis, the matter could not be subjected to judicial review.

Continuation of Services

• The appellants' services were continued through periodic extensions, and they served with DTTDC until 31.12.2014, when their services were discontinued.

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