Guest Lecturers Cannot Claim Regularization or Stop Fresh Selection: Manipur HC

Guest lecturers engaged purely as a temporary stop-gap arrangement have no legal right to claim regularization or block fresh selection processes conducted under updated statutory guidelines. The High Court of Manipur held that the principle restricting the replacement of one set of ad-hoc employees with another does not apply to guest faculty paid on a per-lecture honorarium basis.

A single-judge bench of Justice A. Guneshwar Sharma delivered the ruling while dismissing a batch of writ petitions filed under Article 226 of Constitution of India by former guest lecturers of Government Polytechnic, Imphal. The petitioners challenged government notifications initiating fresh selections and sought regularization of their services alongside back pay.

Court Observations and Directions

The Court observed that the initial engagement orders explicitly stipulated that the appointments were temporary stop-gap arrangements lacking any sanctioned post backing. The bench emphasized that post-28.02.2022, there was no valid administrative extension granted to the petitioners.

The Court, in its reasoning, observed: "The engagement of the petitioners in terms of the initial notice dated 13.02.2008 is not against the sanctioned posts and is purely on engagement basis without any assurance of extension and regularization; (ii) their engagement is purely as stop gap arrangement due to shortage of teaching faculty in Govt. Polytechnic College, Takyel; and (iii) the principles of one contract/adhoc employee cannot be replaced by another set of adhoc/contract employee will not be applicable to the facts of the present cases; (iv) their engagement is not against sanctioned posts and on the basis of per lecture honorarium and they are not paid on the basis of monthly honorarium."

The Court issued the following directions:

"(i) The petitioners and others were engaged on the basis of notice dated 13.02.2008 issued by the Controller of Technical Education, Manipur purely on temporary basis, time bound and as stop gap arrangement;
(ii) Their appointment was never intended against sanctioned posts; the appointment order itself says that they have no right for extension and on the expiry of the last extension on 28.02.2022, there is no further extension; and the proposal for 3 years extension vide letter dated 24.02.2025 of the Controller of Technical Education, Manipur has already been rejected by the Administrative Department, Govt. of Manipur vide letter dated 15.05.2025.
(iii) WP(C) Nos. 905 of 2025, 880 of 2025, 523 of 2025 and 384 of 2026 are dismissed. Interim orders stand vacated.
(iv) The respondents are directed to issue appointment order forthwith to the candidates whose appointment has been stayed by this Court [including respondent No.5 in WP(C) No. 905 of 2025] and the period of 1 year will be counted from the day, the new appointees have taken charge.
(v) MC(WP(C)) Nos. 407 of 2026, 834 of 2025, 502 of 2025, 760 of 2025, 810 of 2025, 870 of 2025 and 388 of 2026 are also disposed of in terms of the above directions & observations.
(vi) Parties are directed to bear their own costs.
(vii) If the petitioners are actually working without any formal extension post 28.02.2022 (as alleged by the petitioners), such period shall be verified by the Controller of Technical Education, Manipur; and the petitioners may claim their entitlement for remuneration for the lectures they have already undertaken. However, the same does not amount to extension of their service by this Court.
(viii) Regarding the plea of regularization, this Court does not express any opinion and the issue is left open to the wisdom of the competent authority to proceed as per rules, if the petitioners are so eligible.
(ix) Registry is directed to send a copy of this judgment to the Controller of Technical Education, Manipur for information and necessary compliance."

Background

The petitioners were initially engaged as Guest Lecturers in 2008 at Government Polytechnic, Imphal following an advertisement. Their engagements were extended periodically with gap days until February 28, 2022. Though the Controller of Technical Education proposed further ex-post facto extension, the Administrative Department rejected it on May 15, 2025. Subsequently, fresh selection notifications were issued under AICTE Regulations incorporating objective criteria like written tests and viva-voce.

The petitioners approached the High Court seeking quashing of the rejection letter, setting aside of the fresh recruitment process, and regularization of their services by citing landmark rulings including Secretary, State of Karnataka vs. Uma Devi ( "(2006) 4 SCC 1": 2006 CaseBase(SC) 148) and Hargurpratap Singh vs. State of Panjab & Ors.. They also relied on Amrinder Kaur vs. State of Punjab and Ors. to argue against temporary replacement. Conversely, state counsel and newly selected candidates relied on principles from Shiv Kumar Sharma vs. Santosh Kumari ( "(2007) 8 SCC 600": 2007 CaseBase(SC) 89) and U.P. State Electricity Board vs. Pooran Chandra Pandey and others to argue that non-sanctioned tenure posts confer no legal rights upon completion of the term.

Dismissing the petitions, the High Court held that the fresh recruitment process under AICTE Regulations was legitimate and directed the issuance of appointment orders to the newly selected candidates.

Case Details:
Case No.: WP(C) No. 905 of 2025 with WP(C) No. 384 of 2026, WP(C) No. 880 of 2025 & WP(C) No. 523 of 2025
Neutral Citation: 2026:MNHC:166
Case Title: Smt. Shanta Keithellakpam v. The State of Manipur & Ors.
Appearances:
For the Petitioner(s): Mr. M. Rendy, Adv., Ms. Gunapriya, Adv., Mr. Ng. Jotindra Luwang, Adv., Ms. W. Geetarani, Adv.
For the Respondent(s): Mr. M. Devananda, Addl. AG, Ms. N. Jyotsana, Adv., Mr. Kh. Tarunkumar, Sr. Adv., Mr. Jamon, Adv., Mr. Rustam, Adv.

Source: 2026 CaseBase(MAN) 5