IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH 112 CWP-21271-2026 (O&M) Date of Decision:- 15.07 .2026 Dharmender Sharma and others … PeƟƟoners Versus State of Haryana and others ... Respondents CORAM: HON'BLE MS. JUSTICE NIDHI GUPTA Present:- Mr. Sandeep Thakan, Advocate, for the peƟƟoners. Ms. Tanushree Gupta, Addl. A G, Haryana. ***** NIDHI GUPTA, J . Present Civil Writ PeƟƟon under ArƟcles 226 of the ConsƟtuƟon of India has been filed by the peƟƟoner for issuance of a writ in the nature of CerƟorari quashing the impugned leƩers No. 794-795 dated 01.07.2026 (P-12), No. 800-802 dated 01.07.2026 (P-13) issued by respondent no. 2, and No. 1051- 1065 dated 08.07.2026 (P-14) issued by respondent no. 4, whereby the services of the peƟƟoners have been arbitrarily terminated; and further issue a writ of mandamus direcƟng the respondents to reinstate/conƟnue the peƟƟoners in service as HKRNL Contractual Employees with conƟnuity of service and all consequenƟal benefits. 2. It is inter alia submiƩed by ld. counsel for the peƟƟoners that the peƟƟoners had joined the respondent-Forest Department on contractual basis through outsourcing agency, namely, Shine and Sind Security SoluƟons Pvt. Ltd. NEELAM KUMARI 2026.07.20 11:01 I attest to the accuracy and authenticity of this document Punjab and Haryana High Court, Chandigarh CWP-21271-2026 (O&M) - 2 - Subsequently peƟƟoners were engaged on their respecƟve posts on contractual basis in the office of respondent No.2/Principal Chief Conservator of Forests (hereinaŌer ‘PCCF’). Since their respecƟve dates of engagement peƟƟoners have conƟnuously and diligently discharged their duƟes to the saƟsfacƟon of the respondents. The Government of Haryana vide leƩer dated 19.01.2022 set up the Haryana Kaushal Rozgar Nigam Limited (here in aŌer ‘HKRNL’) with the mandate of deploying contractual manpower in Govt. Departments/ Boards/ CorporaƟons etc. as per the wage rates prescribed by the Nigam, i.e. the ‘Nigam Wage Rates’. 3. The Government of Haryana also issued Deployment of Contractual Policy 2022 vide noƟficaƟon dated 30.06.2022 (Annexure P-2). The object of this policy was to meet the requirement of short term unskilled and semi-skilled manpower including emergent needs of the Government organizaƟons not above Job Role of Level-III. The HKRNL issued Deployment Offer LeƩers/DOL to persons already working with the respondent department on contractual basis including the peƟƟoners. By way of example, ld. counsel refers to the DOL dated 01.04.2023 (Annexure P-3) issued to peƟƟoner No. 5 herein namely, Sandeep Sahu. Learned counsel submits that thereaŌer, the Haryana Contractual Employees (Security of Service) Act, 2024 (hereinaŌer ‘Act’) came to be enacted vide noƟficaƟon dated 06.12.2024 (Annexure P-4). It is submiƩed that due to the acute shortage of staff, respondent No. 2/PCCF vide leƩer No. 181 dated 20.06.2024 (Annexure P-5) addressed to respondent No. 1/AddiƟonal Chief Secretary, Haryana proposed sancƟon of 72 addiƟonal posts on various categories including Superintendents, Clerks, Drivers, NEELAM KUMARI 2026.07.20 11:01 I attest to the accuracy and authenticity of this document Punjab and Haryana High Court, Chandigarh CWP-21271-2026 (O&M) - 3 - Peons and other Group D staff to enable the department to discharge its statutory funcƟons smoothly. Ld. counsel points out that in the said leƩer dated 20.06.2024, it is specifically recorded that in the absence of the said posts Government work was suffering considerably. 4. It is submiƩed that the respondent No.2/PCCF vide leƩer dated 28.03.2025 (Annexure P-6) also sought renewal of contract of employees working in the renewal of contract of employees appointed through HKRNL for the financial year 2025-2026. It is submiƩed that the said leƩer itself categorized the contractual employees into two categories namely those who had completed 5 years' service as on 15.08.2024 and those who had not. The peƟƟoners, having joined only in the year 2021, fell within the laƩer category, and yet, were expressly shown by respondent no. 2 itself as employees whose services were required to be conƟnued for the year 2025-2026. 5. ThereaŌer the respondent No.2 PCCF vide another leƩer dated 02.04.2025 (Annexure P-7) addressed to respondent No.1/AddiƟonal Chief Secretary, Haryana sought approval for creaƟon/conƟnuaƟon of 36 contractual posts and for extension of the contract of the concerned employees for the financial year 2025-26. The said proposal was reiterated by respondent No.2 and forwarded for Government approval vide leƩer dated 23.04.2025 (Annexure P- 8). ThereaŌer on 03.12.2025, a MeeƟng of the State Board of Wildlife, Haryana was convened under the Chairmanship of Hon'ble Chief Minister in the CommiƩee Room at Haryana Civil Secretariat and 40 HKRN employees were given sancƟon in the said meeƟng; and the Minutes of MeeƟng were issued vide LeƩer No. 400-417 dated 06.01.2026 (Annexure P-9). It is further submiƩed that NEELAM KUMARI 2026.07.20 11:01 I attest to the accuracy and authenticity of this document Punjab and Haryana High Court, Chandigarh CWP-21271-2026 (O&M) - 4 - vide leƩer dated 08.05.2026 (Annexure P-10), respondent No.2 again sent a consolidated proposal to the respondent No.1 for renewal of the contract period of the contractual employees deployed through HKRNL. Vide LeƩer dated 10.6.2026 (Annexure P-11), the respondent-department conveyed its approval for extending contractual engagement of the above said 251 Forest Wing employees, and 22 Wildlife Wing employees for the period 1.4.2026 to 30.6.2026, deployed through HKRNL, subject to compliance with condiƟons contained in Deployment Policy, 2022 et cetera, and other relevant rules and regulaƟons and InstrucƟons. The peƟƟoners' names were missing from the said list. 6. Ld. counsel submits that while asserƟng to implement the aforesaid approval dated 10.06.2026, respondent no. 2 vide Memo No. 794-795 dated 01.07.2026 (Annexure P-12), addressed to the Divisional Wildlife Officers, Gurugram and Panchkula, restricted the benefit of conƟnuaƟon only to those 22 employees of the Wildlife Wing who had completed 5 years' service as on 15.08.2024, being the class of employees protected under the Haryana Contractual Employees (Security of Service) Act, 2024 and directed that no person other than those 22 named employees be conƟnued in service without approval. 7. Ld. Counsel contends that the said Act nowhere mandates or contemplates the automaƟc terminaƟon of contractual employees who have not completed 5 years' service. It merely secures the services of those who have. Respondent no. 2, without any independent applicaƟon of mind to the individual facts and length of service of the remaining similarly situated NEELAM KUMARI 2026.07.20 11:01 I attest to the accuracy and authenticity of this document Punjab and Haryana High Court, Chandigarh CWP-21271-2026 (O&M) - 5 - employees, including the peƟƟoners, mechanically excluded them from the benefit of conƟnuaƟon. It is submiƩed that consequent upon the above, respondent no. 2 issued the impugned LeƩer No. 400-402 dated 01.07.2026 (Annexure P-13), addressed individually to the peƟƟoners no. 1, 2 and 9, and terminated/relieved them from service with immediate effect, solely on the ground that no sancƟoned post is available in the office and that approval has not been received from the Government. It is contented that neither any Show Cause NoƟce was issued to the peƟƟoners nor any opportunity of hearing was afforded nor any reason relatable to their individual conduct, performance, seniority inter se the retained employees or eligibility was assigned prior to passing the impugned LeƩer. 8. Ld. Counsel submits that in conƟnuaƟon and further corroboraƟon of the aforesaid The Divisional Wildlife Officer Gurugram/respondent no. 4, acƟng upon the direcƟons contained in LeƩer bearing reference No. 794-795 dated 01.07.2026 (P-12) and the impugned LeƩer No. 800-802 dated 01.07.2026 (P-13), vide its impugned LeƩer No. 1051-65 dated 08.07.2026 (Annexure P-14), similarly relieved the contractual employees including peƟƟoners no. 17 to 21 who are also HKRNL contractual employees with effect from 01.07.2026 on the similar ground that their names did not figure in the Contract Renewal List for the Financial Year 2026-27 conveyed vide the Government LeƩer dated 10.06.2026. 9. Ld. counsel argues that the impugned leƩers dated 01.07.2026 (Annexures P-12 and P-13) and impugned leƩer dated 08.07.2026 (Annexure P- 14) have been passed in gross violaƟon of the principles of natural jusƟce NEELAM KUMARI 2026.07.20 11:01 I attest to the accuracy and authenticity of this document Punjab and Haryana High Court, Chandigarh CWP-21271-2026 (O&M) - 6 - inasmuch as the peƟƟoners who have been rendering conƟnuous uninterrupted and saƟsfactory service since the year 2021 have been abruptly terminated and deprived of their livelihood without issuance of any show cause noƟce and without being afforded any opportunity of hearing. It is submiƩed that the 2024 Act is a beneficial legislaƟon enacted to secure the services of contractual employees such as the peƟƟoners. It is contended that the said Act has been arbitrarily misapplied to terminate the peƟƟoners without following any raƟonal, fair or non-discriminatory method. 10. It is further submiƩed that the impugned acƟon is violaƟve of ArƟcle 14 of the ConsƟtuƟon of India inasmuch as similarly and even less circumstanced contractual employees engaged through HKRNL in other offices and divisions of the same department performing idenƟcal duƟes have been retained and their contracts have been proposed for renewal. Thus, no intelligible differenƟa has been applied by the respondents while terminaƟng the peƟƟoners. This is especially so as the work/posts against which the peƟƟoners were employed conƟnues to exist. It is pointed out that the respondents' own proposal dated 20.06.2024 (Annexure P-5) for creaƟon of 72 addiƟonal permanent posts remains pending with the Government Ɵll today. 11. Learned counsel further submits that the peƟƟoners have been terminated purely on the administraƟve/budgetary ground of “non-availability of sancƟoned posts”. It is submiƩed that the said situaƟon is enƟrely aƩributable to the respondents' own inacƟon in not geƫng sancƟoned the proposals for 72 addiƟonal posts pending since 20.06.2024. From the above, it is also clear that the peƟƟoners have not been terminated due to any misconduct, inefficiency or NEELAM KUMARI 2026.07.20 11:01 I attest to the accuracy and authenticity of this document Punjab and Haryana High Court, Chandigarh CWP-21271-2026 (O&M) - 7 - adverse performance on their part. It is further pointed out that in numerous similar maƩers this Court including CWP-20616-2026, this Court has been pleased to issue noƟce vide order dated 10.07.2026 (Annexure P-15). It is accordingly prayed that the present writ peƟƟon be allowed; and a writ in the nature of cerƟorari be issued for quashing of impugned LeƩer No. 794-795 dated 01.07.2026 (P-12) passed by respondent no. 2 whereby the services of employees/peƟƟoners deployed through HKRN has been ordered to be terminated; impugned LeƩer No. 800-802 dated 01.07.2026 (P-13) issued by respondent no. 2 whereby the services of peƟƟoners have been terminated; impugned LeƩer No. 1051-1065 dated 08.07.2026 (P-14) issued by respondent no. 4, whereby the peƟƟoners have been terminated, who are contractual employees engaged through HKRNL and have been conƟnuously working since the year 2021, have been abruptly terminated; and issue a writ in the nature of mandamus direcƟng the respondents authoriƟes to conƟnue/reinstate the peƟƟoners in service as HKRNL Contractual Employees with conƟnuity of service and all consequenƟal benefits. 12. Per contra learned counsel for the respondent-State has vehemently opposed submissions advanced on behalf of the peƟƟoners and submiƩed that peƟƟoners' services have been terminated when their contractual deployment came to an end, and the IndenƟng Department decided not to extend the contract of the peƟƟoners due to non-availability of sancƟoned posts. It is further submiƩed that the reliance of the peƟƟoner upon Minutes of the MeeƟng dated 06.01.2026 (Annexure P-9) of the State Board for Wildlife, Haryana as per which there was acute shortage of staff, is misconceived NEELAM KUMARI 2026.07.20 11:01 I attest to the accuracy and authenticity of this document Punjab and Haryana High Court, Chandigarh CWP-21271-2026 (O&M) - 8 - as the ulƟmate approval has to come from the Government of Haryana. It is submiƩed that vide leƩer dated 08.05.2016 (Annexure P-10), respondent No.2- PCCF had also sent a consolidated proposal to the AddiƟonal Chief Secretary, Haryana for renewal of contract period of contractual employees. Similarly, vide leƩer dated 10.06.2026 (Annexure P-11) again request for approval for extending contractual engagement of 251 Forest Wing Employees 22 Wildlife Wing Employees i.e. total 273 employees was sent. However, vide leƩer dated 10.06.2026, the Government of Haryana had given extension only to those 22 employees who were covered under the Act of 2024. Ld. Counsel submits that the same comes within the domain of the Government and not that of the respondent department. Thus, the impugned order suffers from no infirmity. 13. It is further pointed out that as per Clause 5.9 of the Deployment Policy of 2022 (Annexure P-2), it is also sƟpulated that the term of deployment is for a limited period of one year or the period specified in DOL/Deployment Offer LeƩer whichever is earlier. A similar Clause 6 is also contained in all the DOL leƩers issued to the contractual employees, including the peƟƟoners. Therefore, no rights of the peƟƟoners have been violated. It has been clearly stated in the impugned order that there is non-availability of sancƟoned posts. Accordingly, the present writ peƟƟon deserves to be dismissed. 14. No other argument is made on behalf of learned counsel for the parƟes. I have heard ld. counsel and perused the case file and record in detail. I find no merit in the submissions advanced on behalf of the peƟƟoners. 15. The undisputed facts are that the peƟƟoners were previously appointed through outsourcing agency Shine and Sind Security SoluƟons Private NEELAM KUMARI 2026.07.20 11:01 I attest to the accuracy and authenticity of this document Punjab and Haryana High Court, Chandigarh CWP-21271-2026 (O&M) - 9 - Limited on contract basis between the years 2018 to 2023 vide appointment leƩer dated 30.04.2021 (Annexure P-1) (at page 39 of the paper book), issued by the abovesaid ContracƟng Agency in case of peƟƟoner No. 1 i.e. is Dharmender Sharma. Thus, at Ɵme of iniƟal appointment peƟƟoners were not engaged through HKRNL and were not employees of the respondent State, but were employees of their Contractor. Subsequently, peƟƟoners were borne on the portal of HKRNL as evident from Deployment Offer LeƩer dated 25.03.2022 issued to the peƟƟoner No.1 (Annexure P-1) (at page 40 of the paper book). It is not the case of the peƟƟoners that they were appointed prior to cut off date of 15.08.2019 as sƟpulated under the Act of 2024; or that they have worked for a conƟnuous period of five years. It is in fact acknowledged by the peƟƟoners themselves that they were iniƟally appointed on their respecƟve posts through outsourcing agency i.e. is Shine and Sind Security SoluƟons Private Limited on contract basis between the years; and that they were issued deployment offer leƩers by the HKRNL only in the year 2022. Clearly therefore peƟƟoners are not enƟtled to protecƟon under the Act of 2024. 16. It is also not disputed by the peƟƟoners that despite the fact that recommendaƟon dated 10.06.2026 (Annexure P-11) was made by the respondent-department for retaining/extending the contract of 273 employees, the respondent-State of Haryana has retained/extended the contract of only those 22 Wildlife Wing Employees who came under the 2024 Act. Thus, no discriminaƟon is made out against the peƟƟoners. 17. Ld. counsel for the peƟƟoners is also unable to controvert that the Government has given extension only to those employees who are covered NEELAM KUMARI 2026.07.20 11:01 I attest to the accuracy and authenticity of this document Punjab and Haryana High Court, Chandigarh CWP-21271-2026 (O&M) - 10 - under the Act of 2024, i.e. they have rendered 5 years of conƟnuous saƟsfactory service. Whereas, admiƩedly, peƟƟoners are not eligible for protecƟon under the 2024 Act. Therefore, no right accrues to the peƟƟoners. 13. The main thrust of the arguments of ld. counsel for the peƟƟoners has been that the respondent department through the respondent No.2, Principal Chief Conservator of Forests/PCCF, has Ɵme and again submiƩed requisiƟons to the Government of Haryana seeking approval for creaƟon and/or extension of posts of contractual employees. In this regard, ld. counsel for the peƟƟoner has referred in parƟcular to Minutes of MeeƟng dated 06.01.2026 (Annexure P-9) of the State Board for Wildlife, Haryana, wherein as per agenda item 8.10, acute staff shortage at various levels has been highlighted due to increasing workload. However, it is also not disputed that sancƟoned posts are not available. Ld. counsel for the peƟƟoners has been unable to show anything to this Court to remotely indicate that vacancies exist or that any sancƟoned posts are available. In fact, in the impugned order dated 01.07.2026 (Annexure P-13) issued by respondent no.2/PCCF, it is clearly recorded that: “Therefore, due to the non-availability of sancƟoned posts in this office and due to not receiving approval from the Government, you are hereby relieved from this office.” 19. It is further to be seen that a bare reading of the Deployment Offer LeƩers issued to the peƟƟoners carry a sƟpulaƟon that peƟƟoners shall have no right to conƟnue upon expiry of their term. By the way of example, DOL dated 01.04.2023 (Annexure P-3), issued to the peƟƟoner No.5 herein categorically sƟpulates in clause 6 thereof as follows:- NEELAM KUMARI 2026.07.20 11:01 I attest to the accuracy and authenticity of this document Punjab and Haryana High Court, Chandigarh CWP-21271-2026 (O&M) - 11 - “6. The services of the manpower so deployed shall hereinaŌer cease on the expiry of the term and such manpower shall not be enƟtled for any claim for the regularisaƟon/conƟnuaƟon of sevices or any other consequenƟal benefits.” 20. A similar condiƟon is contained in clause 5.9 of the Deployment Policy of 2022/ Annexure P-2, sƟpulaƟng thereby that the term of appointment shall automaƟcally cease upon expiry of contract. The said clause 5.9 is as follows: “5.9 Term of deployment: Under this policy the term of deployment in the first instance shall be for a period of one year or the period specified in the DOL, whichever is earlier. It will cease automaƟcally without providing any claim to the deployed manpower to any conƟnuaƟon of deployment or any consequenƟal benefits. Two months prior to the expiry of the deployment term, the IndenƟng OrganisaƟon, based on the monthly performance appraisal and consent of the deployed manpower, shall submit an extension request for a specified period, less than or equal to a year, subject to approval of Finance Department. AŌer proper examinaƟon, the Nigam shall extend the deployment term for the period specified by the IndenƟng OrganisaƟon through the portal. The manpower so engaged shall not have any legal right for claiming regularizaƟon of his/her services in the IndenƟng OrganisaƟon where he/she has been deployed.” 21. In view of the above discussion, it cannot be said that the impugned order terminaƟng the services of the peƟƟoners is legally infirm as it is admiƩed fact on record that peƟƟoners do not fall within the ambit of protecƟon of the Act of 2024; no discriminaƟon is caused to the peƟƟoners as only those 22 persons have been retained who are eligible for protecƟon under NEELAM KUMARI 2026.07.20 11:01 I attest to the accuracy and authenticity of this document Punjab and Haryana High Court, Chandigarh CWP-21271-2026 (O&M) - 12 - the Act of 2024; no sancƟoned posts are available; and no principles of natural jusƟce can be said to have been violated as peƟƟoners have no legal or vested right to conƟnue in view of the above said clauses contained in the DOL as well as the Deployment Policy of 2022. 22. Keeping in view the aforesaid factual and legal posiƟon, the present writ peƟƟon stands dismissed. 23. Pending applicaƟon(s), if any, also stands disposed of. ( NIDHI GUPTA ) 15.07.2026 JUDGE Neelam Whether speaking /reasoned Yes / No Whether Reportable Yes / No NEELAM KUMARI 2026.07.20 11:01 I attest to the accuracy and authenticity of this document Punjab and Haryana High Court, Chandigarh