Legal Analysis: R. Iyyappan & Ors. vs. Union of India & Ors

Citation: 2026 INSC 431
Court: Supreme Court of India
Bench: Justice Vikram Nath & Justice Sandeep Mehta 
Judgment Author: Justice Vikram Nath
Date of Decision: April 29, 2026
Nature of Judgment: Civil Appeal under Article 136 of the Constitution of India against High Court judgment affirming rejection of regularisation claim.

Synopsis of the Judgment

The appellants were daily-wage workers engaged between 1991 and 1997 at the Mahendragiri Unit of the Liquid Propulsion Systems Centre (LPSC), a premier research and development unit under the Indian Space Research Organisation (ISRO). In 2010, the Central Administrative Tribunal directed the respondents to create requisite posts and frame a scheme for engaging such workers on a “permanent footing”. The respondents instead framed the “Gang Labourers (Employment for Sporadic Types of Work) Scheme, 2012”, which provided only temporary engagement till the age of 60 years. The High Court dismissed the challenge to the scheme. The Supreme Court reversed, holding that the scheme was inconsistent with the binding directions of the Tribunal (which had attained finality). The Court set aside the scheme, directed regularisation of the appellants with permanent status from 9th September 2010, and criticised the State for failing to act as a model employer.

1. Basic Information of the Judgment

Field Details Case Title R. Iyyappan & Ors. vs. Union of India & Ors. Civil Appeal No. Arising out of SLP (Civil) No. 7138 of 2025 Bench Justice Vikram Nath  & Justice Sandeep Mehta Date of Decision April 29, 2026 Citation 2026 INSC 431Appeal From Judgment dated 08.07.2024 of Madras High Court in Writ Petition No. 31674 of 2019

2. Legal Framework

Laws and Principles Involved:

• Constitution of India, 1950: Article 14 (equality – State as model employer), Article 21 (right to livelihood – indirectly invoked), Article 23 (prohibition of forced labour – argued but not applied).

• Service Jurisprudence: Principles of regularisation, distinction between ad‑hoc/daily‑wage engagement and permanent employment; binding nature of final judicial directions; doctrine of res judicata and finality of orders.

• Central Administrative Tribunal Act, 1985: Powers of CAT to issue directions to regularise service conditions.

Precedents Cited:

• State of Karnataka v. Umadevi (2006) 4 SCC 1 – No fundamental right to regularisation; cited by the High Court but distinguished by the Supreme Court on the ground that the earlier CAT directions ha

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