Author: Radhaanjana S, SASTRA Deemed University

The case of Ram Kumar v. Union of India and Ors is a decision of the Hon’ble Supreme Court of India dealing with the rights of casual labourers employed under the Indian Railways. This case highlights the issues related to regularisation of employment, equal pay for equal work and treatment of long-serving temporary workers under public authorities. The case reflects the constitutional commitment under Article 14 and 16 of the constitution, particularly in the context of vulnerable government contract workers. This case analysis examines how the court addressed exploitation that arose from prolonged casual employment and non-implementation of official railway policies. 

Keywords

Contract Labour, Regularisation, Equal Pay, Indian Railways, Employment Equality.

The petitioners were casual labourers employed by the Northern Railway in various departments such as construction and maintenance. Many of them had been working continuously for more than ten years, yet they were not granted temporary status or regularised as permanent employees.

Despite various Railway Board circulars and provisions under the Railway Establishment Manual providing for regularisation of such workers after completion of continuous service, the Railway authorities failed to implement the same. This created a situation where workers doing permanent and essential work were denied benefits of regular employees, including proper wages and service conditions. This led the petitioners to approach the Supreme Court seeking justice.

The petitioners were employed as casual labourers by the Indian Railways for periods ranging between 10 to 16 years. They were assigned duties similar to those performed by regular and temporary railway employees, including maintenance and signaling work.

They contended that:

1. They were entitled to be treated as temporary servants.

2. They should receive equal pay for equal work.

3. They should be considered for absorption into regular service as per railway rules.

However, the Railway administration continued treating them as casual labourers without extending the benefits of temporary or permanent employment.

The case primarily involved the interpretation of:

• Article 14 of the Constitution of India – Equality before law.

• Article 16 of the Constitution of India – Equality of opportunity in public employment.

• Provisions of the Railway Establishment Manual, especially those concerning the conferment of temporary status on casual labourers after a stipulated period of service.

• Railway Board circulars issued regarding absorption and regularization of casual labourers.

The main issues involved in the case were:

1. Whether long-serving casual labourers in Indian Railways are entitled to regularization.

2. Whether they are entitled to equal pay for equal work when performing the same duties as regular employees.

3. Whether the failure of the Railway administration to implement its own policies violates Articles 14 and 16 of the Constitution.

The Supreme Court held that the Railway authorities had failed to carry out their own policies and rules concerning casual labourers. The Court observed that allowing workers to serve for over a decade without granting them temporary or permanent status amounted to arbitrary treatment and exploitation.

The Court directed the Railway authorities to:

• Consider the eligible casual labourers for regularization after proper screening.

• Provide them with wages on par with regular employees performing similar duties, thereby recognizing the principle of equal pay for equal work.

However, it clarified that mere grant of temporary status does not automatically entitle workers to pensionary benefits unless they are confirmed as permanent employees

This judgment reflects the Supreme Court’s concern for social justice and fair treatment of vulnerable workers employed by the State. By directing the implementation of existing rules, the Court did not create new obligations but reinforced accountability of public authorities.

The decision recognizes that prolonged casual employment without dignity and job security violates basic constitutional values. At the same time, the Court maintained a balance by not granting automatic permanency and insisting on proper screening before regularisation.

The case became an important precedent for labour rights, especially in public sector employment. It strengthened the position of casual and temporary workers across government departments and reinforced the principle that artificial classification between workers doing the same job is unconstitutional.

It also influenced later cases such as:

• State of Punjab v. Jagjit Singh (2017) – on equal pay for equal work.

• Cases dealing with contract labour regularisation in PSUs.

This case remains relevant as it exposes how bureaucratic inaction can violate fundamental rights and how judicial intervention can restore fairness.

Ram Kumar v. Union of India is a landmark judgment that reaffirmed the constitutional values of equality and fairness in public employment. It recognized that casual workers performing permanent functions cannot be indefinitely denied employment security and fair wages. The case continues to serve as an important reference point in employment equality and labour law jurisprudence.