Umesh Kumar Sharma & Ors.

IN THE HIGH COURT OF JUDICATURE FOR
RAJASTHAN JAIPUR BENCH AT JAIPUR
S.B. CIVIL WRIT PETITION NO. _________/2023
1. Umesh Kumar Sharma S/O Mohan Lal Sharma

Aged 33 Years Resident Of Village Goner Post Goner
Tehsil Sanganer District Jaipur- 303905
2. Shakti Kumar Saini S/O Mangal Chand Saini Aged
About 28 Year Resident Of Dhani Pahad Singh Wali
Village Divrala Tehsil Shreemadhopur District
Sikar-332701
3. Raj Kumar Sharma S/O Nirmal Kumar Sharma
Aged About 37 Year Resident Of H.No
56,Chandravila Extension Sogariya Tehsil Ladpura
District Kota-324002
4. Giriraj Sharma S/O Mahaveer Sharma Aged About
30 Year Resident Of Near Nagarpalika Lakheri
Tehsil Indergarh District Bundi-323615
5. Chhotu Lal Saini S/O Gyarasi Lal Aged About 51
Year Resident Of Ward No 10 Shankarpura Lakheri
6. Jeetendra Kumar Rajora S/O Durga Shanker
Rajora Aged About 40 Year Resident Of Mohalla
Nayapura Lakheri Tehsil Indargadh District Bundi-
323603
7. Dharmendra Kumar S/O Bhanwar Pal Singh Aged
About 33 Year Resident Of Village Nagla Sukhdev
Post Neemkhera Tehsil Jalesar District Etah UP-
207302
8. Suresh Kumar Jangid S/O Kailash Chand Jangid
Aged About 39 Year Resident Of Vpo Bhajera Tehsil
Reni District Alwar-301409
9. Trilok Chand Mahawar S/O Pooran Mal Koli Aged
About 33 Year Resident Of Vpo Hingotiya Tehsil
Lawan District Dausa-303303
10. Indrajeet Gochar S/O Gopi Lal Gochar Aged About
32 Year Resident Of Railway Station Lakheri
District Bundi-323603
11. Ram Kishor Prajapat S/O Babu Lal Aged About 27
Year Resident Of Village Dev Nagar Harsuliya Tehsil
madhorajpura District Jaipur-303904
12. Ramesh Kumar S/O Mahaveer Prasad Aged About
33 Year Resident Of Vpo Dumoli Khurd Tehsil
Buhana District Jhunjhunu-333516
13. Umakant S/O Shanker lal Aged About 42 Year
Resident Of Village Lakheri Tehsil Indargarh District
Bundi-323603
14. Lekhraj Meena S/O Shankar Lal Meena Aged About
29 Year Resident Of Village Kharli Bhitoli Post
Kakarala Tehsil Bamanwas District Sawai
Madhopur-322211
15. Vishnu Kumar Sharma S/O Shankar Lal Sharma
Aged About 35 Year Resident Of Village New Rajyas
Tehsil phulia Kalan District Bhilwada-311407
16. Naval Prakash Regar S/O Prabhu Lal Regar Aged
About 40 Year Resident Of Vpo Itunda Tehsil
Jahazpur District Bhilwara-311201
17. Ravi Kumar Khati S/O Kalu Ram Khati Aged About
27 Year Resident Of vpo Ghatiyali Tehsil Sawar
District Ajmer-305407
18. Rajender Prashad S/O Gopi Ram Aged About 41
Year Resident Of Village Bajar Post Ganiyar Tehsil
Ateli Mandi District Mahendergarh HR-123021
19. Shankar Lal Singoria S/O Ram Niwas Aged About
31 Year Resident Of Plat No 36 Sitaram Nagar
Triveni Nagar Gopalpura Bypass Durgapura Tehsil
Sanganer District Jaipur-3032018
20. Vijender Kumar Saini S/O Prithvi Raj Saini Aged
About 37 Year Resident Of Village Lakheri Post
Lakheri Tehsil Indragarh District Bundi-323603
21. Dheeraj Kumar Jat S/O Bhanwar Lal Jat Aged
About 28 Year Resident Of Village Pander Tehsil
22. Anil Kumar Sharma S/O Nag Bhushan Sharma
Aged About 52 Year Resident Of 661/41
Nashingpura Jones ganj District Ajmer-305001
23. Naveen jangid S/O Omprakash Aged About 27 Year
Resident Of 1436 A/41 Gali No 8 Shivnagar Bihari
Ganj District Ajmer -305001
24. Mayur Kachhawa S/O Jagdish Prasad Kachhawa
Aged 35 Years Resident Of F-4 Godawari Bhawan,
Shalimar Colony Gali No 2 Adarsh Nagar, Ajmer
305001
25. Dilip Kumawat S/O Ramchandra Kumawat Aged 37
Years Resident Of Kothabas Pisangan Vill Pisangan
District Ajmer 305204
26. Som Praksh Pareek S/O Om Praksh Pareek Aged 44
Years Resident Of Near Anaj Godown Purohitan
Mohalla Tehsil Fagi District Jaipur-303005
27. Preeti Tomar D/O Sher Singh Tomar Aged 35 Years
Resident Of I-E-8 Behind Gurudwara Kansuwa-4
Udyog Puri District Kota-324004
28. Dana Ram Heengra S/O Shri Babu Ram Heengra
Aged 37 Years Resident Of Moole ke talab ke pas
gaffur batta District jaisalmer -345001
29. Ramnaresh Bishnoi S/O Sahab Ram Bishnoi Aged
32 Years Resident Of Bishnoi Mandir Ke Piche
Ward No 24 Rawatsar District Hanumangarh-
335524
30. Bhoop Singh S/O Manphool Ram Aged 47 Years
Resident Of Vpo lalana Ward No 2 Tehsil Nohar
District hanumanghar-335504
31. Bajrang Lal S/O Ram Kumar Aged 35 Years
Resident Of Chak-17 LM Post-15 LM Tehsil
Anupgarh District Shri Ganganagar-335703
32. Pramod Kumar S/O Sita Ram Verma Aged 56 Years
Resident Of 2-M-5 Housing Board Tehsil Banswara
District Banswara-327001
33. Jagender Kumar Saini S/O Govind Ram Saini Aged
46 Years Resident Of Chokri Wali Dhani Ward No
19 Village Shrimadhopur Tehsil Shrimadhopur
District Sikar-332715
34. Mahesh Chand Yadav S/O Mohan Singh Yadav
Aged 32 Years Resident Of Vpo Alamshah Tehsil
Nagar District Bharatpur-321024
35. Surya Prakash Saini S/O Nand Kishor Saini Aged
33 Years Resident Of Namrata Nagar Ke Paas
Devpura Tehsil Bundi District Bundi-323001
36. Sevaram Gurjar S/O Jagdish Lal Gurjar Aged 35
Years Resident Of Village Chhan Bas Suriya Post
Barwas Tehsil Todaraisingh District Tonk-304505
37. Vishnu Kumar Choudhary S/O Ratan Lal Jat Aged
34 Years Resident Of Village Parasiya Post Tonk
Tehsil Tonk District Tonk-304001
38. Praveen Joshi S/O Jagdish Joshi Aged 44 Years
Resident Of Mangalpura Ward No 5 Tehsil Pokaran
District Jaisalmer-345021
39. Khengar Ram S/O Tara Ram Aged 35 Years
Resident Of Vpo Nananayai Tehsil Pokaran District
Jaisalmer-345021
40. Rohit Davera S/O Prakash Chand Sharma Aged 33
Years Resident Of 33 Shastri Colony Near Power
HouseTehsil Bijainagar District Ajmer-305624
41. Satya Narayana Sharma S/O Chunni Lal Sharma
Aged 29 Years Resident Of Jai Nagar Post
Shambhugarh Tehsil Asind District Bhilwara-
311204
42. Jagdish Prasad Verma S/O Ram Dayal Regar Aged
38 Years Resident Of Vpo Umar Teshil Hindoli
43. Rahul Regar S/O Ramdev Regar Aged 29 Years
Resident Of Vpo Umar Teshil Hindoli District
Bundi-323025
44. Mukesh Kumar Regar S/O Ramdev Regar Aged 32
Years Resident Of Vpo Umar Teshil Hindoli District
Bundi-323025
45. Laxman Ram S/O Mishra Ram Aged 32 Years
Resident Of Vpo Chelak Tehsil Fatehgarh District
Jaisalmer-345001
46. Vahid Khan S/O Sabir Khan Aged 34 Years
Resident Of Near Ghanta Ghar Tehsil Bari District
Dholpur-328021
47. Nijamuddin Khan S/O Afajal Khan Aged 29 Years
Resident Of Ward No 34 Near Agra Bus Stand Tehsil
Rajakhera District Dholpur-328025
48. Vikarm Saini S/O Nand Lal Saini Aged 39 Years
Resident Of Kisan Nuasary Samod Road Tehsil
Chomu District Jasipur-303702
49. Bajrang Lal Yadav S/O Ganpat Lal Yadav Aged 31
Years Resident Of Ward o 07 Nadiya Gram Singod
Khurd Tehsil Chomu District Jaipur-303803
50. Sher Singh S/O Pooran Singh Aged 33 Years
Resident Of Vpo Moroli Kalan Tehsil Bharatpur
District Bharatpur-321025
51. Ashok Kumar Sharma S/O Mata Prasad Sharma
Aged 37 Years Resident Of 26/299 Near Surajpol
Chouraha Gulalkund Tehsil Bharatpur District
Bharatpur-321001
52. Navratan Saini S/O Suraj Mal Saini Aged 34 Years
Resident Of Samod Road Gidha Wali KOthi Ward No
42 Tehsil Chomu District Jaipur-303702
53. Mahendra Kumar Sharma S/O Murlidhar Sharma
Aged 46 Years Resident Of Ganash Nagar Indra
Colony Tehsil Chomu District Jaipur-303702
54. Bharosi Lal Bairwa S/O Gangaram Bairwa Aged 31
Years Resident Of Vpo Bhanwarawara Tehsil Nadoti
District Karauli- 322213
55. Pramod Saini S/O Kelash Saini Aged 29 Years
Resident Of Bhagt Watika Ward No 01 Tehsil
Chomu District Jaipur-303702
56. Arvind Kumar Saini S/O Buddha Ram Saini Aged
28 Years Resident Of Bawdi Walo Ki Dhani Ward No
30 Tehsil Lalsot District Dausa-303511
57. Om Prakash Mokala S/O Kachara Ram Mokala
Aged 44 Years Resident Of Vpo Thirod Tehsil
Marwad Mundwa District Nagor-341026
58. Rohitash Kumar Jat S/O Ram Karan Jat Aged 30
Years Resident Of Vpo Shivsinghpura Tehsil
Shahpura District Jaipur-303806
59. Narendra Kumar S/O Sahab Singh Aged 36 Years
Resident Of Village Jodhla Post Mehrawar Tehsil
Bharatpur District Bharatpur-321201
60. Salig Ram Kumawat S/O Ganesh Lal Kumawat
Aged 33 Years Resident Of Village Akodra Post
Rampura Tehsil Mavli District Udaipur-313203
61. Devendra Sen S/O Shri Kailash Chandra Aged 37
Years Resident Of 101 Gali No 04 Opposite B N
College Subhash Nagar Tehsil Girwa District
Udaipur -313001
62. Jamna Kumari Nagda D/O Chunni Lal Nagda Aged
38 Years Resident Of 1361 Abhinandan Colony Near
Akashansh Complex Shastri Circle Kushal Bag
Tehsil Girwa District Udaipur-313001
63. Ghanshyam Joshi S/O Shanti Lal Joshi Aged 31
Years Resident Of Village Phalashiya Post
Phalashiya Tehsil jhadol District Udaipur-313701
64. Jagdish Lal Garg S/O Narayan Lal Garg Aged 36
Years Resident Of 56 Bhoiyon Ki Pancholi District
Udaipur -313003
Resident Of Jodhela Post Mehawar Tehsil Kumher
66. Vikram Saini S/O Sh.Nand lal Verma Aged 38 Years
Resident Of Kishan Nursary Samod Road Chomu
Tehsil Chomu District Jaipur-303702
67. Mahendra Kumar Sharma S/O Murli Dhar Sharma
Aged 47 Years Resident Of Indra Colony Tehsil
68. Vikram Singh S/O Om Prakash Aged 28 Years
Resident Of Ward No 12 Chhani Bari Tehsil Bhadra
District Hanumangarh - 335511
69. Devi Singh S/O Mohan Singh Aged 47 Years
Resident Of Gaudapada Tehsil Gaudapada District
Jaisalmer -345001
70. Nehpal Singh S/O Guman Singh Aged 31 Years
Resident Of Kila Parking Dhibba Pada District
Jaisalmer – 345001
71. Ravi Kumar S/O Nemi Chand Nai Aged 38 Years
Resident Of Gaudapada Naiyo ka Chouk
Kishanghat Ki Prol darjipada District Jaisalmer-
345001
72. Poonam Kumari D/O Girraj Prasad Aged 28 Years
Resident Of JP Nagar (Meena Colony) Delhi Road
Tehsil Alwar District Alwar – 301001
73. Pradeep Verma S/O Magni Ram Verma Aged 46
Years Resident Of 53,54,55 Gali No 14 Sanganer
Colony Bhilwara District Bhilwara-311011
74. Om Prakash Gotam S/O Raja Ram Gotam Aged 38
Years Resident Of H No 197 Dream Lalnd Colony
Hanumangarh Junction District Hanumangarh -
335512
75. Deepak Kumar S/O Desh Raj Aged 33 Years
Resident Of Ward No 04 Naw Khunja Hanumangarh
Junction District Hanumangarh -335512
76. Akashdeep Joshi S/O Shriram Joshi Aged 34 Years
Resident Of H No 196 Sector No 11 A Ward No 08
335512
…Petitioners
Versus
1. State of Rajasthan through the Principal Secretary,
Department of Personnel, Main Building,
Government Secretariat, Jaipur (Raj.)
Department of Skill, Employment &
Entrepreneurship, Directorate of Technical
Education, Government Secretariat, Jaipur (Raj.)
3. The Director, Department of Skill, Employment &
Education Directorate of Technical Education, W-6,
Residency Road, Jodhpur-342011, Rajasthan
4. Regional Director, Regional Directorate of Skill,
Employment & Entrepreneurship, havintg its office
at National Skill Training Institute, Jhalana
Doongri, Jaipur.
5. The Deputy Director, Technical Education
(Training), Zonal Office, Kota
(Training), Zonal Office, Jodhpur
(Training), Zonal Office, Jaipur
(Training), Zonal Office, Ajmer
(Training), Zonal Office, Udaipur
(Training), Zonal Office, Bharatpur
(Training), Zonal Office, Bikaner
….Respondents
S.B. WRIT PETITION UNDER ARTICLE 226

OF THE CONSTITUTION OF INDIA
AND
IN THE MATTER OF ARTICLE 14,16,AND 21
OF THE CONSTITUTION OF INDIA
AND
IN THE MATTER OF PRINCIPLES OF
NATURAL JUSTICE
To
The Hon’ble Chief Justice and his other Hon’ble
Companion Judges of the Rajasthan High Court,
Bench at Jaipur
MAY IT PLEASE YOUR LORDSHIPS,
The humble petitioners, above named, most

respectfully beg to submit as under:-
1. That the petitioners are Citizens of India and the

cause of action has arisen within the jurisdiction of
this Hon’ble High Court, therefore, they are entitled
to invoke the extraordinary jurisdiction of this
Hon’ble Court under Article 226 of the Constitution
of India for redressal of the legal / fundamental
rights & genuine grievances as mentioned in the
present petition.
2. That on 01.11.2006 the State Government issued
an order for filling the post of Junior Instructors in
the different I.T.I. Colleges of the State of Rajasthan.
For kind perusal and ready reference copy of the
order dated 01.11.2006 is annexed and marked as
Annexure-1.
3. That prior to it on 17.10.2006, a Fax was sent by
the Principal Secretary, Technical Education an
instructions were given that in the I.T.I. Colleges
(Industrial Training Institutes) in the trades the
students have taken admission and if the post of
Instructor of that Trade is vacant then such post
should be filled by 31.10.2006 by engaging the
employee on contract basis and the arrangement for
teaching the students should be made. Thus the
order dated 01.11.2006 was issued in furtherance
of the earlier directions issued on 17.10.2006 which
finds reference in the order dated 01.11.2006 itself.
4. That accordingly many candidates the State of
Rajasthan were appointed as Junior Instructors in
the respective Trades it goes without saying that
such candidates were possessing the requisite
qualification for being appointed as Junior
Instructors in the Industrial Training Institutes in
accordance with the prevailing service rules
governing the appointments at that time.
5. That as a matter of fact thereafter, on 31.12.2008
again similar kind of order was issued by the special
Officer Technical Education and directions were
issued to the Director, Technical Education
providing job chart and fixed amount of Rs.
10,000/- to be paid to such Junior Instructor per
month. For ready reference copy of the order dated
31.12.2008 is annexed and marked as Annexure-2.
6. That thereafter, on 27.04.2012 an order was issued
for filling up the vacant post of Instructors through
agency i.e. placement agencies / contractor on Job
basis. It is significant to mention here that such
placement agency was engaged by way of inviting
tenders through the concerned Principal /
Superintendent of the Industrial Training Institute
and candidates were engaged as Junior Instructors.
For ready reference copy of the order dated
7. That thereafter, on 25.04.2013 again an order was
issued by the Joint Secretary of Technical
Education granting permission for engagement on
job basis. Copy of the order dated 25.04.2013 is
annexed and marked as Annexure-4.
8. That further on 11.09.2014 an order was issued for
engagement of the Junior Instructors. Copy of the
order dated 11.09.2014 is annexed and marked as
Annexure-5.
9. That thus in this sequence continuous orders were
issued from time to time. Copy of the order dated
Copy of the order dated 02.03.2016 is annexed and
marked as Annexure-7.
10. That on 28.02.2017 the Director, Technical
Education also sent a letter to all the concerned
Principal / Superintendent / Manager of the
Industrial Training Institute for engagement of the
Junior Instructors. Copy of the letter dated
11. That thereafter, within a period of only 02 months
again a letter was issued to all the Principal /
Superintendent / Managers of the Industrial
Training Institute for engaging the Junior
Instructors under Guest Faculty. For ready
reference copy of the letter dated 03.04.2017 is
12. That in the Guest Faculty the respondents provided
the scheme that they will be paid Rs. 200/- per
period and for practical classes Rs. 55/- per period
and maximum limit of Rs. 10,000/- was also fixed
therein. Though the respondents provided that
preference will be given to the retired employees and
if such persons are not available then the Guest
Faculty candidates may be engaged for training.
13. That the humble petitioners are those candidates
who were engaged by the respondents from time to
time on the post of Junior Instructor which is given
in the form a table as under, the date of their
engagement and since then they are continuing
with the respondents.
14. That the letter dated 03.04.2017 was issued on the
basis of the order dated 23.03.2017 issued by the
Joint Secretary of the Technical Education
Department. For ready reference copy of the order
dated 23.03.2017 issued by the Joint Secretary of
the Technical Education Department is annexed
and marked as Annexure-10.
15. That after this arrangement was going on however,
after 01.04.2020 respondents started paying Rs.
270/- per period and Rs. 80/- per period for
practical teaching and maximum limit was fixed as
Rs. 14000/- and thereafter, from 15.06.2023 the
the respondents issued a new order by which they
sought to make payment of Rs. 300/- per period
and Rs. 150/- per period for practical examination.
For ready reference copy of the order dated
15.06.2023 is annexed and marked as Annexure-
11. Copies of the appointment orders of few
candidates issued in 2020 and onwards are
annexed and marked as Annexure-12 colly.
16. That for other few candidates experience certificates
revealing they are working from the date of their
engagement showing total duration of the service
rendered by them are annexed and marked as
Annexure-13 colly.
17. That earlier the respondents were not issuing
appointment orders to the candidates who were
engaged by them but since presently the
respondents are following the mechanism of Guest
Faculty by directly engaging the candidates through
Principals of the concerned ITIs and the
Superintendents of concerned ITIs and Manager of
the concerned ITIs therefore, there is direct
relationship of the petitioners with the respondents
and the State Government is the Principal employer.
18. That thus the respondents are also required to
follow the provisions of the notification dated
11.01.2022 issued by the respondents in regard to
the contractual employees under the provisions of
the Rajasthan Contractual Hiring to Civil Post
Rules, 2022. For ready reference copy of the
Rajasthan Contractual Hiring to Civil Post Rules,
2022 is annexed and marked as Annexure-14.
19. That on the basis of these Rules the Chief Secretary
of State of Rajasthan also sent letter to all the
Departments, Corporations, Boards, Subsidiaries,
Universities, Autonomous Bodies etc. for adopting
the Rules of 2022 issued under notification dated
11.01.2022. Copy of the letter dated 10.03.2022
issued by the Chief Secretary of the State of
Rajasthan is annexed and marked as Annexure-15.
20. That though this is the policy and intention of the
Government to get this notification of 11.01.2022
adopted by all the departments and all the
institutions under the aegis of the State
Government including Universities also as also the
Boards, Corporations but the respondents are not
adopting these Rules for the engagement of the
Junior Instructors who are working for years
together since year 2006 as per the scheme of the
respondents.
21. That thus the respondents are subjected to
discrimination by the Department of Technical
Education (Training) itself and therefore, serious
prejudice are caused to the interest of the
petitioners.
22. That the exploitation of the humble petitioners is to
such an extend that with the end of the academic
session they discontinue the petitioners who are
working as Junior Instructors and the salary of the
period of summer vacation is also not being paid to
the petitioners, however, thereafter, again with the
new session respondents engage the humble
petitioners and they do not replace the petitioners
by another set of contractual employee as they are
continuing for years together with the respondents
as revealed from the table mentioned in this writ
petition.
23. That in the all Government Departments the salary
of the period of vacation during vacations are also
being paid. Since the petitioners cannot have any
other job during this period because again with the
starting of the academic session the will have to
continue with the concerned institute where they
are engaged therefore, the non-employment of
period of vacations is unwarranted. The
respondents cannot exploit the services of the
petitioners as the State in suppose to be Welfare
State and cannot be an exploitative state and
therefore, interference by this Hon'ble Court is also
liable to be made to that extent, in the interest of
justice.
24. That the humble petitioners have also availed
information under RTI Act which reveals that there
are 3144 posts of Juniors Instructors vacant in the
State of Rajasthan and there are 143 posts of Group
Instructors there are 2177 posts of Trade
Instructors and there are 283 posts of Computer
Instructors (IT) and there are 504 posts of
Engineering Drawing / Workshop Calculation and
180 posts of Employment Skill Instructors. For kind
perusal and ready reference copy of the information
provided under letter dated 04.11.2022 is annexed
25. Thus the facts situation is that 3144 posts of
Juniors Instructors are lying vacant against which a
few of the humble petitioners are continuing for
years together, some have are continuing for last
more than 17 years and still they are facing the
situation of unemployment for certain period of
vacations and again they are being engaged but for
a very meager amount.
26. That be that as it may the facts remains that the
petitioners are duly qualified persons, the
respondents selected them and they are continuing
and discharging of their duties very efficiently, in
fact their job chart and work is akin to the regularly
appointed Juniors Instructors and there is no
difference in their duties and responsibilities and
job chart. They also impart the same duties as
regular employees are discharging on the post of
Juniors Instructors.
27. That on 2021 there are total 2,43,120 seats of ITI
available for the State of Rajasthan according to the
report of the Neei Aayog issued by the Government
of India for year 2023. That according to the report
of the Niti Aayog there are total 18817 position
which are sanctioned out of which only 15.99%
positions were added by regular mode. That the
information provided by the respondents under
letter dated 04.11.2022 is also provided much less
then what the actual position is reflected from the
report of the Neeti Aayog. Copy of the relevant part
of the report of Neeti Ayog is annexed and marked
as Annexure-17.
28. That be that as it may the facts remains that
regular recruitments are not being made for many
years and whatever the recruitment are made very
less in number in comparison to the post which are
vacant, thus continuance of this arrangement of
contractual nature since 2006 in itself is reflecting
that in the most arbitrary and uncalled manner,
respondents are exploiting the poor bargaining
position of the petitioners.
29. That at this juncture the humble petitioners who
are working for many years have also become
overage for regular recruitment and it is also a fact
situation that the policy of the State Government to
impart bonus marks for those who are working and
imparting similar duties in different department like
for the post of Nursing Officer, for the post of
Ayurved Chikitsadhikari which is a gazetted post,
for the post of Homophony Chikitsadhikari, for the
post of Unani Chikitsadhikari, for the post of LDC in
Panchayati Raj Department as also for the post of
Lab Technician, for the post of Pharmacist etc. thus
if the humble petitioners are even allow to
participate in the direct recruitment, it becomes
very difficult for them compete as they are also they
have invested their whole youth in imparting
education in the ITI and now they will not be able to
compete with the fresh candidates, so the benefit of
bonus marks are also required to be granted to the
petitioners for regular recruitment, whenever the
recruitment are held.
30. That after 30.06.2023 the petitioners have been
discontinued by the respondents as they
discontinue the humble petitioners for a period of
03 months in a most arbitrary and uncalled for
manner for the sake of reference of the Hon'ble
Court an office order dated 27.06.2023 is annexed
31. That all the offices of the ITI are run and opened
and other regular staffs are working and they are
being paid regular salary. However, the exploitation
of the humble petitioners is to such an extend even
they are not paid salary of period of 03 months in a
year which is highly unwarranted and uncalled for.
32. That one hand the State Government is not issuing
regular recruitment on the other hand the duly
qualified persons who are working for years together
are exploited in this manner. Thus this whole
concept of guest faculty is contrary the scheme of
the Rules. Under the Rules either the Urgent
Temporary Basis appointment can be made or
regular recruitment can be made.
33. That even those who are engaged on contractual
basis in the State of Rajasthan and as per the
Scheme of the Rules of 2022 there is no scope of
any artificial break of 03 months for the employees.
The survival of an employee who is being paid such
a meager amount is difficult for a period of 03
months.
34. That the process of admission has been initiated in
the month of May, 2023 and these admissions
process will continue August 2023 and thereafter
regular classes will also be initiated. Copy of the
schedule given by the D.G.T. Government of India,
Ministry of Skill Development Entrepreneurship
Director of Training dated 27.04.2023 is annexed
and marked as Annexure-19. Copy of the Schedule
of admission in the State of Rajasthan downloaded
from the website of the respondents is annexed and
35. That the rules governing recruitment of Junior
Instructor are Rajasthan Technical Training
Subordinate Service Rules, 1975. Copy of the
relevant part of the Rajasthan Technical Training
Subordinate Service Rules, 1975 is annexed and
36. That due to summer vacation the services of the
humble petitioners were discontinued after
conducting the examination in the month of June
2023 from 01.07.2023 from service, every year this
kind of arrangement, the respondents use to
undertake and again with the start of new session
the services of the petitioners are continuing every
time the respondents are not issuing advertisement
for engagement of the Guest Faculty Junior
Instructors.
37. That at many places the respondents issued
advertisement again but the humble petitioners who
were continuing for many years are continued this
kind of rigor of selection every year is unwarranted
and uncalled for specially when the services are to
be hired on contractual basis this is a kind of
replacement by another set of contractual
employees by the State Government this is not
permissible in the eye of law.
38. That again this year the respondents have issued
advertisement for different institutes on 02.08.2023
and again the respondents are seeking to engage
the Junior Instructors with the similar qualification
which was possessed by the humble petitioners at
the time of their initial appointment or engagement
before 10 years or more. Now respondents are again
subjecting the petitioners to the rigor of selection
and this is nothing but replacement of the
contractual employee by another set of contractual
employee in the garb of a fresh advertisement for
contractual employees by the respondents. Though
similar kind of advertisement was issued earlier
which was faced by the petitioner and they are
continuing and this advertisement was issued again
and again every year for last more than 10 years,
petitioners faced each and every year the rigor of
selection and continued after having confronted
such situation now the humble petitioners have
knocked at the doors of this Honb'ble High Court as
this policy of the respondents subject the petitioners
for a selection process every year though it is a
contractual employment is uncalled for the gap of
about 2 to 3 months in between after examination is
also uncalled for, this result in violation of the legal
and fundamental rights of the humble petitioners
and therefore, interference is liable to be made by
this Hon'ble Court.
39. That vide Circular dated 02.03.2023, the State
Government has sought that the candidates who
have undergone the course of CITS will only be
appointed as Instructor. Copy of Letter/Circular
datd 02.03.2023 is annexed and marked as
Annexure-22.
40. That the respondents have also subsequently issued
Orders for fresh appointments in which also the
qualification of CITS has been made mandatory.
Copy of one such Order dated 04.08.2023 is
41. That the Letter dated 02.03.2023 also finds a
reference of the Letter dated 29.09.2022 issued by
the Skill Development and Entrepreneurship. Copy
of the Letter dated 29.09.2022 is annexed and
42. That under the Letter dated 17.06.2022, the
Director Training of the Technical Education,
Directorate asked for undertaking RPL course as
per CITS syllabus, ......... Designed RPL Scheme and
those persons who are not holding the course of
CITS/RPL were only to be considered for such
syllabus/scheme and it was required to be applied
all those Instructors who are working and have not
undertaken CITS course, this was for all such
working and regular Instructors according to the
eligibility provided by the Central Government,
Director General of Training but the petitioners who
were working on contract basis as Instructor were
not considered for RPL by the State Government
and they were not allowed. Though they have also
applied by way of submitting registration but
subsequently, such applications were blocked. For
the sake of instance, the copy of the receipt of fees
and registration of one candidate is annexed and
marked as Annexure-25 collectively. Copy of the
Letter dated 17.06.2022 is also annexed and
43. That in the latest amendment notification issued on
01.09.2023, the CITS is also one of the essential
qualification for the post of the ................. The copy
of the relevant part of the Rules i.e. Rajasthan
Technical Training Subordinate Service (Second
Amendment) Rules, 2023 issued under Notification
dated 01.09.2023 by which schedule of the
Technical Training Subordinate Service Rules, 1975
has been substituted is annexed and marked as
Annexure-27. Thus, the RPL scheme/CITS is
essential for appointment as Junior Instructor and
also for further promotion to the post of Senior
Instructor thus, the humble petitioners who are
working on contractual basis are also required to be
allowed to undertake this course which is of a 3
months duration as per the RPL scheme designed
by the Director General of Training. The eligiblity of
Instructor for appearing in AITT under RPL is as
under:
"4.0 Eligibility instructor for appearing in AITT
under RPL
(i) The aspirant should have basic
qualification viz. CTS/diploma/degree in
that broad sector.
(ii) The aspirant should have a minimum age
limit of 25 years and a maximum age
limit of 62 years on specified cut-off date.
(iii) The instructor (regular/contractual (long
term contract)) having at least 03 years of
experience of teaching the institute.
(iv) The instructor should be sponsored by
the institute for applying in this scheme
to appear in AITT for RPL under CITS to
be conducted by DGT or could apply on
his/her own.
(v) The instructor has to be registered
National Instructional Medical institute
(NIMI) online portal at least two months
before the scheduled date of examination.
(vi) The instructor has to submit experience/
service certificate from State Directorate/
Principal.
(vii) In case of candidates claiming experience
from Pvt. ITIs, should produce EPF/ESCI
slip."
Copy of the modified guidelines for recognition of
prior learning under Craft Instructor Training
Schemne issued on 26.04.2022 is annexed and
44. That the RPL (Recognition of Prior Learning) under
Craft Instructor Training Scheme (CITS) is thus,
made an essential qualification under the latest
amendment made on 01.09.2023 and humble
petitioners are also willing and intending being
eligible to pursue this court, therefore, respondents
may also be directed to conduct this course of the
humble petitioners otherwise, the humble
petitioners who are working for last more than a
decade/many years would be deprived of their right
to participate in the selection process for regular
recruitment as and when the advertisement would
be issued. Thus, the humble petitioners are also
required to be equipped with the required eligibility
qualification of RPL by the respondents for which
they are also required to be directed for undertaking
the RPL course at the earliest.
45. That out of the present petitioners around 30
persons possess the CITS Certificate but most of
them are not in possession of CITS Certificate
therefore, such interference is also liable to be made
for those who do not have CITS qualification and for
all the petitioners, the aspect of replacement of
contractual employee by another set of contractual
employee is required to be considered and
accordingly liable to be interfered by this Hon'ble
Court.
46. That thus the humble petitioners have preferred the
present writ petition on the following other
grounds:-
GROUNDS
a) Because, in the Guest Faculty the respondents
provided the scheme that they will be paid Rs.
200/- per period and for practical classes Rs. 55/-
per period and maximum limit of Rs. 10,000/- was
also fixed therein. Though the respondents provided
that preference will be given to the retired
employees and if such persons are not available
then the Guest Faculty candidates may be engaged
for training.
b) Because, the humble petitioners are those
candidates who were engaged by the respondents
from time to time on the post of Junior Instructor
which is given in the form a table as under, the date
of their engagement and since then they are
continuing with the respondents.
c) Because, after this arrangement was going on
however, after 01.04.2020 respondents started
paying Rs. 270/- per period and Rs. 80/- per period
for practical teaching and maximum limit was fixed
as Rs. 14000/- and thereafter, from 15.06.2023 the
the respondents issued a new order by which they
sought to make payment of Rs. 300/- per period
and Rs. 150/- per period for practical examination.
d) Because, earlier the respondents were not issuing
appointment orders to the candidates who were
engaged by them but since presently the
respondents are following the mechanism of Guest
Faculty by directly engaging the candidates through
Principals of the concerned ITIs and the
Superintendents of concerned ITIs and Manager of
the concerned ITIs therefore, there is direct
relationship of the petitioners with the respondents
and the State Government is the Principal employer.
e) Because, thus the respondents are also required to
follow the provisions of the notification dated
11.01.2022 issued by the respondents in regard to
the contractual employees under the provisions of
the Rajasthan Contractual Hiring to Civil Post
Rules, 2022.
f) Because, on the basis of these Rules the Chief
Secretary of State of Rajasthan also sent letter to all
the Departments, Corporations, Boards,
Subsidiaries, Universities, Autonomous Bodies etc.
for adopting the Rules of 2022 issued under
notification dated 11.01.2022.
g) Because, though this is the policy and intention of
the Government to get this notification of
11.01.2022 adopted by all the departments and all
the institutions under the aegis of the State
Government including Universities also as also the
Boards, Corporations but the respondents are not
adopting these Rules for the engagement of the
Junior Instructors who are working for years
together since year 2006 as per the scheme of the
respondents.
h) Because, the exploitation of the humble petitioners
is to such an extend that with the end of the
academic session they discontinue the petitioners
who are working as Junior Instructors and the
salary of the period of summer vacation is also not
being paid to the petitioners, however, thereafter,
again with the new session respondents engage the
humble petitioners and they do not replace the
petitioners by another set of contractual employee
as they are continuing for years together with the
respondents as revealed from the table mentioned
in this writ petition.
i) Because, in the all Government Departments the
salary of the period of vacation during vacations are
also being paid. Since the petitioners cannot have
any other job during this period because again with
the starting of the academic session the will have to
continue with the concerned institute where they
are engaged therefore, the non-employment of
period of vacations is unwarranted. The
respondents cannot exploit the services of the
petitioners as the State in suppose to be Welfare
State and cannot be an exploitative state and
therefore, interference by this Hon'ble Court is also
liable to be made to that extent, in the interest of
justice.
j) Because, thus the facts situation is that 3144 posts
of Juniors Instructors are lying vacant against
which a few of the humble petitioners are
continuing for years together, some have are
continuing for last more than 17 years and still they
are facing the situation of unemployment for certain
period of vacations and again they are being
engaged but for a very meager amount.
k) Because, be that as it may the facts remains that
the petitioners are duly qualified persons, the
respondents selected them and they are continuing
and discharging of their duties very efficiently, in
fact their job chart and work is akin to the regularly
appointed Juniors Instructors and there is no
difference in their duties and responsibilities and
job chart. They also impart the same duties as
regular employees are discharging on the post of
l) Because, on 2021 there are total 2,43,120 seats of
ITI available for the State of Rajasthan according to
the report of the Niti Aayog issued by the
Government of India for year 2023. That according
to the report of the Niti Aayog there are total 18817
position which are sanctioned out of which only
15.99% positions were added by regular mode. That
the information provided by the respondents under
letter dated 04.11.2022 is also provided much less
then what the actual position is reflected from the
report of the Niti Aayog.
m) Because, be that as it may the facts remains that
regular recruitments are not being made for many
years and whatever the recruitment are made very
less in number in comparison to the post which are
vacant, thus continuance of this arrangement of
contractual nature since 2006 in itself is reflecting
that in the most arbitrary and uncalled manner,
respondents are exploiting the poor bargaining
position of the petitioners.
n) Because, at this juncture the humble petitioners
who are working for many years have also become
overage for regular recruitment and it is also a fact
situation that the policy of the State Government to
impart bonus marks for those who are working and
imparting similar duties in different department like
for the post of Nursing Officer, for the post of
Ayurved Chikitsadhikari which is a gazetted post,
for the post of Homophony Chikitsadhikari, for the
post of Unani Chikitsadhikari, for the post of LDC in
Panchayati Raj Department as also for the post of
Lab Technician, for the post of Pharmacist etc. thus
if the humble petitioners are even allow to
participate in the direct recruitment, it becomes
very difficult for them compete as they are also they
have invested their whole youth in imparting
education in the ITI and now they will not be able to
compete with the fresh candidates, so the benefit of
bonus marks are also required to be granted to the
petitioners for regular recruitment, whenever the
o) Because, all the offices of the ITI are run and
opened and other regular staffs are working and
they are being paid regular salary. However, the
exploitation of the humble petitioners is to such an
extend even they are not paid salary of period of 03
months in a year which is highly unwarranted and
uncalled for.
p) Because,one hand the State Government is not
issuing regular recruitment on the other hand the
duly qualified persons who are working for years
together are exploited in this manner. Thus this
whole concept of guest faculty is contrary the
scheme of the Rules. Under the Rules either the
Urgent Temporary Basis appointment can be made
or regular recruitment can be made.
q) Because, even those who are engaged on
contractual basis in the State of Rajasthan and as
per the Scheme of the Rules of 2022 there is no
scope of any artificial break of 03 months for the
employees. The survival of an employee who is being
paid such a meager amount is difficult for a period
of 03 months.
r) Because other ground will be submitted at the time
of arguments.
s) Because the petitioners have no other alternative
and efficacious remedy except to invoke the
extraordinary jurisdiction of this Hon’ble Court
under Article 226 of the Constitution of India.
PRAYER
It is, therefore humbly prayed that Your Lordship
may graciously be pleased to accept and allow this writ

petition and by an appropriate writ, order or direction:-
1. The arrangement continued for engaging the

petitioners for the scheme of Guest Faculty in itself
may be declared arbitrary and illegal and

accordingly be quashed and set aside.
2. The respondents may be directed to allow the

petitioners to continue for all the 12 months as also
make salary of the all 12 months.

3. Minimum protection may be directed to be granted
to the petitioner not to be replaced by another set of

employees in this manner through new vacancies.
The principle of last come first go may be directed to

be applied by the respondents
4. Due to transfer of regular be selected persons the

services of the petitioners may be ordered not to be
discontinued and the respondents may be directed

to adjust them at the nearby places against the
available vacant post.

5. The respondents may be directed to include the
services of the petitioners also under the

Contractual Hiring of Civil Servant Rules, 2022 i.e.
under notification dated 11.01.2022.

6. The respondents may also be directed to issue
experience certificate to the humble petitioners for

working they have rendered and the same may also
be ordered to be considered for the purpose of

award of bonus marks for the regular recruitment
and this policy may be directed to be formulated

like other departments in the State of Rajasthan.
7. The respondents may also be directed to provide the

course of RPL under CITS which is one of the
essential qualification for the post of Junior

Instructor at the earliest so that before any
advertisement is issued by the State Government,

the petitioners who are working on contract basis
may also be equipped with the minimum eligiblity

qualification, in the interest of justice.
8. Any other appropriate order, which may be found

just and proper in the facts and circumstances of
the case, be passed in favour of the petitioners.
HUMBLE PETITIONERS
THROUGH COUNSEL
[TANVEER AHAMAD]
Advocate
NOTES:-
1. This is S.B. Civil Writ Petition as no vires of any Act
is under challenge.
2. That no such similar writ petition prior to this has
been filed by the petitioners before any competent
court of law.
3. That PF, Notices and extra sets shall be filed as per
direction of the Hon’ble Court.
4. That Pie papers were not readily available; as such
the writ petition has been typed on stout papers by
my private steno.
[TANVEER AHAMAD]
Advocate
R/2303/2003
Mobile no. 9829604104
E-mail id : advocatetanveerahmed@gmail.com
S.B. CIVIL WRIT PETITION NO. ________/2023
Umesh Kumar Sharma & Ors.

Versus
State of Rajasthan & Ors.
AFFIDAVIT IN SUPPORT OF WRIT PETITION

I, Umesh Kumar Sharma S/O Mohan Lal Sharma
Tehsil Sanganer District Jaipur- 303905, do hereby take
oath and state as under:-
1. That I am one of the Petitioners in the above

mentioned case therefore, I am well conversant with
the facts and circumstances of the case.
2. That the annexed writ petition has been drafted by my

counsel under my instructions. I have gone from
Para No. 1 to 46 and grounds (a) to (s) thereof along
with prayer clause of the same and I have read over
the same and understood the same.
3. That the statements in the writ petition are true and

correct.
VERIFICATION
I, the above named deponent, do hereby verify that

the contents of paras 1 to 3 of my above affidavit are true
and correct. Nothing material has been concealed
therein and no part of it is false. So help me God.
S.B. CIVIL MISC. STAY APPLICATION NO……../2023

IN
S.B. CIVIL WRIT PETITION NO. _______/2023

Sikar-332701
323603
207302
Bundi-323603
Madhopur-322211
305001
335524
Jaisalmer-345021
311204
Bundi-323025
Bundi-323025
Jaisalmer-345001
Dholpur-328021
Bharatpur-321001
Udaipur -313001
Udaipur -313003
Jaisalmer -345001
345001
335512
335512
…Petitioners
Versus
Department of Personnel, Main Building,
Government Secretariat, Jaipur (Raj.)
Department of Skill, Employment &
Education, Government Secretariat, Jaipur (Raj.)
3. The Director, Department of Skill, Employment &
Education Directorate of Technical Education, W-6,
Residency Road, Jodhpur-342011, Rajasthan
4. Regional Director, Regional Directorate of Skill,
Employment & Entrepreneurship, havintg its office
at National Skill Training Institute, Jhalana
Doongri, Jaipur.
(Training), Zonal Office, Kota
(Training), Zonal Office, Jodhpur
(Training), Zonal Office, Jaipur
(Training), Zonal Office, Ajmer
(Training), Zonal Office, Udaipur
(Training), Zonal Office, Bharatpur
(Training), Zonal Office, Bikaner
….Respondents
S.B. CIVIL MISC. STAY APPLICATION

UNDER ARTICLE 226 OF THE
CONSTITUTION OF INDIA
To
The Hon’ble Chief Justice and his other Hon’ble
Companion Judges of the Rajasthan High Court,
Bench at Jaipur
MAY IT PLEASE YOUR LORDSHIPS,
The humble petitioners-applicants above named,

most respectfully beg to submit as under:-
1. That the petitioners have preferred annexed writ

petition numbered above, contents of the writ
petition may kindly be treated as part and parcel of
this stay application also for the sake of bulkiness
and brevity.
2. That humble petitioners have a strong prima-facie

case in their favour, balance of convenience also lies
in their favour and if petitioners are not granted
interim protection, they will face irreparable loss
and injury, which cannot be compensated in terms
of money.
3. That principle of natural justice and equity also
demands that the interim order be passed in favour
of the petitioners.
PRAYER
It is, therefore, humbly prayed that this stay

application may kindly be allowed and during the
pendency of the writ petition, till the respondents provide
the course of RPL under CITS, the respondents may be
restrained form asking from the petitioner to have such
qualification as they are working for last many years
already with the respondents and it was the duty of the
respondents to permit the petitioners to undertake this
course in which the State Government has miserably
failed thus, till such course is provided and petitioners
are permitted to undertake such course, respondents
may be directed not to insist for such course from the
petitioner, in the interest of justice.
the respondents may be directed to allow the humble

petitioner to continue and not to be discontinued by way
of new advertisement or by way of new persons engaged
at the place of the petitioners or by way of transfer of any
other regularly selected Junior Instructors at the places
of the humble petitioners and in that eventuality at least
the respondents may be directed to accommodate the
petitioners at the nearby place available and having the
vacant position, in the interest of justice.
Any other appropriate order, which may be found
just and proper in the facts and circumstances of the
case, be passed in favour of the petitioners.
HUMBLE PETITIONERS-APPLICANTS
THROUGH COUNSEL
Jaipur
Dated : ________/2023
Tanveer Ahamad
(Advocate)
NOTES:-
1. That no such application has been filed previously
before this Hon'ble Court.
2. PF, Notices and extra sets shall be filed as per
direction of the Hon’ble Court.
3. Pie papers were not readily available; as such the
stay application has been typed on stout papers by
my private steno.
Tanveer Ahamad
(Advocate)
R/2303/2003
Mobile no. 9829604104
S.B. CIVIL MISC. STAY APPLICATION NO……../2023

IN
Versus
AFFIDAVIT IN SUPPORT OF STAY APPLICATION

1. That I am one of the Petitioners-Applicants in the

above mentioned case therefore, I am well
conversant with the facts and circumstances of the
case.
2. That the annexed application has been drafted by
my counsel under my instructions. I have gone from
Para No. 1 to Para No. 3 of the same and I have read
over the same and understood the same.
3. That the statements in the application are true and
correct.
VERIFICATION
the contents of paras 1 to 3 of my above affidavit are true
and correct. Nothing material has been concealed

Versus
AFFIDAVIT IN SUPPORT OF DOCUMENTS

1. That I am one of the petitioners, and therefore, I am

fully conversant with the facts and circumstances of
the present case.
2. That the Annexure-1 to Annexure-28 annexed with

this writ petition are the true and correct photostat
copies of their originals / downloaded from the
website of the respondents.
VERIFICATION

the contents of paras 1 and 2 of my above affidavit are
true and correct. Nothing material has been concealed

Versus
State of Raj & Ors.
INDEX
Sl. Page No.
Particulars
No.
1. Writ Petition
2. Affidavit in support of Writ Petition
3. Stay Application
4. Affidavit in support of Application
5. Documents:
Annexure-1 - Copy of the order dated
01.11.2006
31.12.2008
27.04.2012
Annexure-4 -Copy of the order dated
25.04.2013
11.09.2014
15.05.2015
02.03.2016
Annexure-8 -Copy of the letter dated
28.02.2017
Annexure-9 -Copy of the letter dated
03.04.2017
Annexure-10 - Copy of the order
dated 23.03.2017 issued by the Joint
Secretary of the Technical Education
Department
Annexure-11 - Copy of the order
dated 15.06.2023
Annexure-12 colly. -Copies of the
appointment orders of few candidates
issued in 2020 and onwards
Annexure-13 - Copy of the experience
certificates of the petitioners
Annexure-14 - Copy of the Rajasthan
Contractual Hiring to Civil Post Rules,
2022
Annexure-15 - Copy of the letter dated
10.03.2022 issued by the Chief
Secretary of the State of Rajasthan
Annexure-16 - Copy of the
information provided under letter
dated 04.11.2022
Annexure-17 - Copy of the relevant
part of the report of Neeti Ayog
Annexure-18 - Copy of the office order
dated 27.06.2023
Annexure-19 -Copy of the schedule
given by the D.G.T. Government of
India, Ministry of Skill Development
Entrepreneurship Director of Training
dated 27.04.2023
Annexure-20 -Copy of the Schedule of
admission in the State of Rajasthan
Annexure-21- Copy of the relevant
part of the Rajasthan Technical
Training Subordinate Service Rules,
1975
Annexure-22- Copy of Letter/Circular
datd 02.03.2023
Annexure-23- Copy of one such Order
dated 04.08.2023
Annexure-24- Copy of the Letter dated
29.09.2022
Annexure-25- copy of the receipt of
fees and registration of one candidate
(Colly)
Annexure-26- Copy of the Letter dated
17.06.2022
Annexure-27- copy of the relevant
part of the Rules i.e. Rajasthan
Technical Training Subordinate
Service (Second Amendment) Rules,
2023 issued under Notification dated
01.09.2023 by which schedule of the
Technical Training Subordinate
Service Rules, 1975
Annexure-28- Copy of the modified
guidelines for recognition of prior
learning under Craft Instructor
Training Schemne issued on
26.04.2022
6. Affidavit in support of documents
[TANVEER AHAMAD]
Advocate
Versus
SYNOPSIS
 That on 01.11.2006 the State Government issued an order for

filling the post of Junior Instructors in the different I.T.I.
Colleges of the State of Rajasthan.
 That prior to it on 17.10.2006, a Fax was sent by the Principal
Secretary, Technical Education an instructions were given that
in the I.T.I. Colleges (Industrial Training Institutes) in the trades
the students have taken admission and if the post of Instructor
of that Trade is vacant then such post should be filled by
31.10.2006 by engaging the employee on contract basis and the
arrangement for teaching the students should be made. Thus
the order dated 01.11.2006 was issued in furtherance of the
earlier directions issued on 17.10.2006 which finds reference in
the order dated 01.11.2006 itself.
 That accordingly many candidates the State of Rajasthan were
appointed as Junior Instructors in the respective Trades it goes
without saying that such candidates were possessing the
requisite qualification for being appointed as Junior Instructors
in the Industrial Training Institutes in accordance with the
prevailing service rules governing the appointments at that
time.
 That as a matter of fact thereafter, on 31.12.2008 again similar
kind of order was issued by the special Officer Technical
Education and directions were issued to the Director, Technical
Education providing job chart and fixed amount of Rs. 10,000/-
to be paid to such Junior Instructor per month.
 That thereafter, on 27.04.2012 an order was issued for filling
up the vacant post of Instructors through agency i.e. placement
agencies / contractor on Job basis. It is significant to mention
here that such placement agency was engaged by way of
inviting tenders through the concerned Principal /
Superintendent of the Industrial Training Institute and
candidates were engaged as Junior Instructors.
 That on 28.02.2017 the Director, Technical Education also sent
a letter to all the concerned Principal / Superintendent /
Manager of the Industrial Training Institute for engagement of
the Junior Instructors.
 That thereafter, within a period of only 02 months again a letter
was issued to all the Principal / Superintendent / Managers of
the Industrial Training Institute for engaging the Junior
Instructors under Guest Faculty.
 That in the Guest Faculty the respondents provided the scheme
that they will be paid Rs. 200/- per period and for practical
classes Rs. 55/- per period and maximum limit of Rs. 10,000/-
was also fixed therein. Though the respondents provided that
preference will be given to the retired employees and if such
persons are not available then the Guest Faculty candidates
may be engaged for training.
 That the humble petitioners are those candidates who were
engaged by the respondents from time to time on the post of
Junior Instructor which is given in the form a table as under,
the date of their engagement and since then they are continuing
with the respondents.
 That after this arrangement was going on however, after
01.04.2020 respondents started paying Rs. 270/- per period
and Rs. 80/- per period for practical teaching and maximum
limit was fixed as Rs. 14000/- and thereafter, from 15.06.2023
the the respondents issued a new order by which they sought to
make payment of Rs. 300/- per period and Rs. 150/- per period
for practical examination.
 That earlier the respondents were not issuing appointment
orders to the candidates who were engaged by them but since
presently the respondents are following the mechanism of Guest
Faculty by directly engaging the candidates through Principals
of the concerned ITIs and the Superintendents of concerned ITIs
and Manager of the concerned ITIs therefore, there is direct
relationship of the petitioners with the respondents and the
State Government is the Principal employer.
 That thus the respondents are also required to follow the
provisions of the notification dated 11.01.2022 issued by the
respondents in regard to the contractual employees under the
provisions of the Rajasthan Contractual Hiring to Civil Post
Rules, 2022.
 That on the basis of these Rules the Chief Secretary of State of
Rajasthan also sent letter to all the Departments, Corporations,
Boards, Subsidiaries, Universities, Autonomous Bodies etc. for
adopting the Rules of 2022 issued under notification dated
11.01.2022.
 That though this is the policy and intention of the Government
to get this notification of 11.01.2022 adopted by all the
departments and all the institutions under the aegis of the
State Government including Universities also as also the
Boards, Corporations but the respondents are not adopting
these Rules for the engagement of the Junior Instructors who
are working for years together since year 2006 as per the
scheme of the respondents.
 That the exploitation of the humble petitioners is to such an
extend that with the end of the academic session they
discontinue the petitioners who are working as Junior
Instructors and the salary of the period of summer vacation is
also not being paid to the petitioners, however, thereafter, again
with the new session respondents engage the humble
petitioners and they do not replace the petitioners by another
set of contractual employee as they are continuing for years
together with the respondents as revealed from the table
mentioned in this writ petition.
 That in the all Government Departments the salary of the
period of vacation during vacations are also being paid. Since
the petitioners cannot have any other job during this period
because again with the starting of the academic session the will
have to continue with the concerned institute where they are
engaged therefore, the non-employment of period of vacations is
unwarranted. The respondents cannot exploit the services of
the petitioners as the State in suppose to be Welfare State and
cannot be an exploitative state and therefore, interference by
this Hon'ble Court is also liable to be made to that extent, in the
interest of justice.
 Thus the facts situation is that 3144 posts of Juniors
Instructors are lying vacant against which a few of the humble
petitioners are continuing for years together, some have are
continuing for last more than 17 years and still they are facing
the situation of unemployment for certain period of vacations
and again they are being engaged but for a very meager
amount.
 That be that as it may the facts remains that the petitioners are
duly qualified persons, the respondents selected them and they
are continuing and discharging of their duties very efficiently, in
fact their job chart and work is akin to the regularly appointed
Juniors Instructors and there is no difference in their duties
and responsibilities and job chart. They also impart the same
duties as regular employees are discharging on the post of
 That on 2021 there are total 2,43,120 seats of ITI available for
the State of Rajasthan according to the report of the Niti Aayog
issued by the Government of India for year 2023. That
according to the report of the Niti Aayog there are total 18817
position which are sanctioned out of which only 15.99%
positions were added by regular mode. That the information
provided by the respondents under letter dated 04.11.2022 is
also provided much less then what the actual position is
reflected from the report of the Niti Aayog.
 That be that as it may the facts remains that regular
recruitments are not being made for many years and whatever
the recruitment are made very less in number in comparison to
the post which are vacant, thus continuance of this
arrangement of contractual nature since 2006 in itself is
reflecting that in the most arbitrary and uncalled manner,
respondents are exploiting the poor bargaining position of the
petitioners.
 That at this juncture the humble petitioners who are working
for many years have also become overage for regular
recruitment and it is also a fact situation that the policy of the
State Government to impart bonus marks for those who are
working and imparting similar duties in different department
like for the post of Nursing Officer, for the post of Ayurved
Chikitsadhikari which is a gazetted post, for the post of
Homophony Chikitsadhikari, for the post of Unani
Chikitsadhikari, for the post of LDC in Panchayati Raj
Department as also for the post of Lab Technician, for the post
of Pharmacist etc. thus if the humble petitioners are even allow
to participate in the direct recruitment, it becomes very difficult
for them compete as they are also they have invested their
whole youth in imparting education in the ITI and now they will
not be able to compete with the fresh candidates, so the benefit
of bonus marks are also required to be granted to the
petitioners for regular recruitment, whenever the recruitment
are held.
 That all the offices of the ITI are run and opened and other
regular staffs are working and they are being paid regular
salary. However, the exploitation of the humble petitioners is to
such an extend even they are not paid salary of period of 03
months in a year which is highly unwarranted and uncalled for.
 That one hand the State Government is not issuing regular
recruitment on the other hand the duly qualified persons who
are working for years together are exploited in this manner.
Thus this whole concept of guest faculty is contrary the scheme
of the Rules. Under the Rules either the Urgent Temporary
Basis appointment can be made or regular recruitment can be
made.
 That even those who are engaged on contractual basis in the
State of Rajasthan and as per the Scheme of the Rules of 2022
there is no scope of any artificial break of 03 months for the
employees. The survival of an employee who is being paid such
a meager amount is difficult for a period of 03 months.
Hence this writ petition.
[TANVEER AHAMAD]
Advocate
REGD. ADDRESS :
S.B.C.W. PETITION NO.………………………./2023

Versus
THAT in the above case registered address of the

petitioners are

Sikar-332701
323603
207302
Bundi-323603
Madhopur-322211
305001
335524
Jaisalmer-345021
311204
Bundi-323025
Bundi-323025
Jaisalmer-345001
Dholpur-328021
Bharatpur-321001
Udaipur -313001
Udaipur -313003
Jaisalmer -345001
345001
335512
335512
VAKALATNAMA
Case_SBCW Petition No._____________/2023
Versus
KNOW ALL MEN by these present that I/ we the undersigned,
1. Umesh Kumar Sharma S/O Mohan Lal Sharma Aged 33

Years Resident Of Village Goner Post Goner Tehsil Sanganer
District Jaipur- 303905
2. Shakti Kumar Saini S/O Mangal Chand Saini Aged About 28
Year Resident Of Dhani Pahad Singh Wali Village Divrala
Tehsil Shreemadhopur District Sikar-332701
3. Raj Kumar Sharma S/O Nirmal Kumar Sharma Aged About
37 Year Resident Of H.No 56,Chandravila Extension
Sogariya Tehsil Ladpura District Kota-324002
4. Giriraj Sharma S/O Mahaveer Sharma Aged About 30 Year
Resident Of Near Nagarpalika Lakheri Tehsil Indergarh
5. Chhotu Lal Saini S/O Gyarasi Lal Aged About 51 Year
Resident Of Ward No 10 Shankarpura Lakheri Tehsil
Indergarh District Bundi-323603
6. Jeetendra Kumar Rajora S/O Durga Shanker Rajora Aged
About 40 Year Resident Of Mohalla Nayapura Lakheri Tehsil
Indargadh District Bundi-323603
7. Dharmendra Kumar S/O Bhanwar Pal Singh Aged About 33
Year Resident Of Village Nagla Sukhdev Post Neemkhera
Tehsil Jalesar District Etah UP-207302
8. Suresh Kumar Jangid S/O Kailash Chand Jangid Aged
About 39 Year Resident Of Vpo Bhajera Tehsil Reni District
Alwar-301409
9. Trilok Chand Mahawar S/O Pooran Mal Koli Aged About 33
Year Resident Of Vpo Hingotiya Tehsil Lawan District Dausa-
303303
10. Indrajeet Gochar S/O Gopi Lal Gochar Aged About 32 Year
Resident Of Railway Station Lakheri District Bundi-323603
11. Ram Kishor Prajapat S/O Babu Lal Aged About 27 Year
Resident Of Village Dev Nagar Harsuliya Tehsil
12. Ramesh Kumar S/O Mahaveer Prasad Aged About 33 Year
Resident Of Vpo Dumoli Khurd Tehsil Buhana District
Jhunjhunu-333516
13. Umakant S/O Shanker lal Aged About 42 Year Resident Of
Village Lakheri Tehsil Indargarh District Bundi-323603
14. Lekhraj Meena S/O Shankar Lal Meena Aged About 29 Year
Resident Of Village Kharli Bhitoli Post Kakarala Tehsil
Bamanwas District Sawai Madhopur-322211
15. Vishnu Kumar Sharma S/O Shankar Lal Sharma Aged
About 35 Year Resident Of Village New Rajyas Tehsil phulia
Kalan District Bhilwada-311407
16. Naval Prakash Regar S/O Prabhu Lal Regar Aged About 40
Year Resident Of Vpo Itunda Tehsil Jahazpur District
Bhilwara-311201
17. Ravi Kumar Khati S/O Kalu Ram Khati Aged About 27 Year
Resident Of vpo Ghatiyali Tehsil Sawar District Ajmer-
305407
18. Rajender Prashad S/O Gopi Ram Aged About 41 Year
Resident Of Village Bajar Post Ganiyar Tehsil Ateli Mandi
District Mahendergarh HR-123021
19. Shankar Lal Singoria S/O Ram Niwas Aged About 31 Year
Resident Of Plat No 36 Sitaram Nagar Triveni Nagar
Gopalpura Bypass Durgapura Tehsil Sanganer District
Jaipur-3032018
20. Vijender Kumar Saini S/O Prithvi Raj Saini Aged About 37
Year Resident Of Village Lakheri Post Lakheri Tehsil
Indragarh District Bundi-323603
21. Dheeraj Kumar Jat S/O Bhanwar Lal Jat Aged About 28
Year Resident Of Village Pander Tehsil Jahazpur District
Bhilwara-311202
22. Anil Kumar Sharma S/O Nag Bhushan Sharma Aged About
52 Year Resident Of 661/41 Nashingpura Jones ganj
23. Naveen jangid S/O Omprakash Aged About 27 Year Resident
Of 1436 A/41 Gali No 8 Shivnagar Bihari Ganj District
Ajmer -305001
24. Mayur Kachhawa S/O Jagdish Prasad Kachhawa Aged 35
Years Resident Of F-4 Godawari Bhawan, Shalimar Colony
Gali No 2 Adarsh Nagar, Ajmer 305001
25. Dilip Kumawat S/O Ramchandra Kumawat Aged 37 Years
Resident Of Kothabas Pisangan Vill Pisangan District Ajmer
305204
26. Som Praksh Pareek S/O Om Praksh Pareek Aged 44 Years
Resident Of Near Anaj Godown Purohitan Mohalla Tehsil
Fagi District Jaipur-303005
27. Preeti Tomar D/O Sher Singh Tomar Aged 35 Years Resident
Of I-E-8 Behind Gurudwara Kansuwa-4 Udyog Puri District
Kota-324004
28. Dana Ram Heengra S/O Shri Babu Ram Heengra Aged 37
Years Resident Of Moole ke talab ke pas gaffur batta District
jaisalmer -345001
29. Ramnaresh Bishnoi S/O Sahab Ram Bishnoi Aged 32 Years
Resident Of Bishnoi Mandir Ke Piche Ward No 24 Rawatsar
District Hanumangarh-335524
30. Bhoop Singh S/O Manphool Ram Aged 47 Years Resident
Of Vpo lalana Ward No 2 Tehsil Nohar District
hanumanghar-335504
31. Bajrang Lal S/O Ram Kumar Aged 35 Years Resident Of
Chak-17 LM Post-15 LM Tehsil Anupgarh District Shri
Ganganagar-335703
32. Pramod Kumar S/O Sita Ram Verma Aged 56 Years Resident
Of 2-M-5 Housing Board Tehsil Banswara District
Banswara-327001
33. Jagender Kumar Saini S/O Govind Ram Saini Aged 46 Years
Resident Of Chokri Wali Dhani Ward No 19 Village
Shrimadhopur Tehsil Shrimadhopur District Sikar-332715
34. Mahesh Chand Yadav S/O Mohan Singh Yadav Aged 32
Years Resident Of Vpo Alamshah Tehsil Nagar District
Bharatpur-321024
35. Surya Prakash Saini S/O Nand Kishor Saini Aged 33 Years
Resident Of Namrata Nagar Ke Paas Devpura Tehsil Bundi
36. Sevaram Gurjar S/O Jagdish Lal Gurjar Aged 35 Years
Resident Of Village Chhan Bas Suriya Post Barwas Tehsil
Todaraisingh District Tonk-304505
37. Vishnu Kumar Choudhary S/O Ratan Lal Jat Aged 34 Years
Resident Of Village Parasiya Post Tonk Tehsil Tonk District
Tonk-304001
38. Praveen Joshi S/O Jagdish Joshi Aged 44 Years Resident Of
Mangalpura Ward No 5 Tehsil Pokaran District Jaisalmer-
345021
39. Khengar Ram S/O Tara Ram Aged 35 Years Resident Of Vpo
Nananayai Tehsil Pokaran District Jaisalmer-345021
40. Rohit Davera S/O Prakash Chand Sharma Aged 33 Years
Resident Of 33 Shastri Colony Near Power HouseTehsil
Bijainagar District Ajmer-305624
41. Satya Narayana Sharma S/O Chunni Lal Sharma Aged 29
Years Resident Of Jai Nagar Post Shambhugarh Tehsil Asind
District Bhilwara-311204
42. Jagdish Prasad Verma S/O Ram Dayal Regar Aged 38 Years
Resident Of Vpo Umar Teshil Hindoli District Bundi-323025
43. Rahul Regar S/O Ramdev Regar Aged 29 Years Resident Of
Vpo Umar Teshil Hindoli District Bundi-323025
44. Mukesh Kumar Regar S/O Ramdev Regar Aged 32 Years
Resident Of Vpo Umar Teshil Hindoli District Bundi-323025
45. Laxman Ram S/O Mishra Ram Aged 32 Years Resident Of
Vpo Chelak Tehsil Fatehgarh District Jaisalmer-345001
46. Vahid Khan S/O Sabir Khan Aged 34 Years Resident Of Near
Ghanta Ghar Tehsil Bari District Dholpur-328021
47. Nijamuddin Khan S/O Afajal Khan Aged 29 Years Resident
Of Ward No 34 Near Agra Bus Stand Tehsil Rajakhera
District Dholpur-328025
48. Vikarm Saini S/O Nand Lal Saini Aged 39 Years Resident Of
Kisan Nuasary Samod Road Tehsil Chomu District Jasipur-
303702
49. Bajrang Lal Yadav S/O Ganpat Lal Yadav Aged 31 Years
Resident Of Ward o 07 Nadiya Gram Singod Khurd Tehsil
50. Sher Singh S/O Pooran Singh Aged 33 Years Resident Of
Vpo Moroli Kalan Tehsil Bharatpur District Bharatpur-
321025
51. Ashok Kumar Sharma S/O Mata Prasad Sharma Aged 37
Years Resident Of 26/299 Near Surajpol Chouraha
Gulalkund Tehsil Bharatpur District Bharatpur-321001
52. Navratan Saini S/O Suraj Mal Saini Aged 34 Years Resident
Of Samod Road Gidha Wali KOthi Ward No 42 Tehsil Chomu
District Jaipur-303702
53. Mahendra Kumar Sharma S/O Murlidhar Sharma Aged 46
Years Resident Of Ganash Nagar Indra Colony Tehsil
54. Bharosi Lal Bairwa S/O Gangaram Bairwa Aged 31 Years
Resident Of Vpo Bhanwarawara Tehsil Nadoti District
Karauli- 322213
55. Pramod Saini S/O Kelash Saini Aged 29 Years Resident Of
Bhagt Watika Ward No 01 Tehsil Chomu District Jaipur-
303702
56. Arvind Kumar Saini S/O Buddha Ram Saini Aged 28 Years
Resident Of Bawdi Walo Ki Dhani Ward No 30 Tehsil Lalsot
District Dausa-303511
57. Om Prakash Mokala S/O Kachara Ram Mokala Aged 44
Years Resident Of Vpo Thirod Tehsil Marwad Mundwa
District Nagor-341026
58. Rohitash Kumar Jat S/O Ram Karan Jat Aged 30 Years
Resident Of Vpo Shivsinghpura Tehsil Shahpura District
Jaipur-303806
59. Narendra Kumar S/O Sahab Singh Aged 36 Years Resident
Of Village Jodhla Post Mehrawar Tehsil Bharatpur District
Bharatpur-321201
60. Salig Ram Kumawat S/O Ganesh Lal Kumawat Aged 33
Years Resident Of Village Akodra Post Rampura Tehsil Mavli
District Udaipur-313203
61. Devendra Sen S/O Shri Kailash Chandra Aged 37 Years
Resident Of 101 Gali No 04 Opposite B N College Subhash
Nagar Tehsil Girwa District Udaipur -313001
62. Jamna Kumari Nagda D/O Chunni Lal Nagda Aged 38 Years
Resident Of 1361 Abhinandan Colony Near Akashansh
Complex Shastri Circle Kushal Bag Tehsil Girwa District
Udaipur-313001
63. Ghanshyam Joshi S/O Shanti Lal Joshi Aged 31 Years
Resident Of Village Phalashiya Post Phalashiya Tehsil jhadol
District Udaipur-313701
64. Jagdish Lal Garg S/O Narayan Lal Garg Aged 36 Years
Resident Of 56 Bhoiyon Ki Pancholi District Udaipur -
313003
65. Narendra Kumar S/O Sahab Singh Aged 36 Years Resident
Of Jodhela Post Mehawar Tehsil Kumher District Bharatpur-
321201
Resident Of Kishan Nursary Samod Road Chomu Tehsil
67. Mahendra Kumar Sharma S/O Murli Dhar Sharma Aged 47
Years Resident Of Indra Colony Tehsil Chomu District
Jaipur-303702
68. Vikram Singh S/O Om Prakash Aged 28 Years Resident Of
Ward No 12 Chhani Bari Tehsil Bhadra District
Hanumangarh - 335511
69. Devi Singh S/O Mohan Singh Aged 47 Years Resident Of
Gaudapada Tehsil Gaudapada District Jaisalmer -345001
70. Nehpal Singh S/O Guman Singh Aged 31 Years Resident Of
Kila Parking Dhibba Pada District Jaisalmer – 345001
71. Ravi Kumar S/O Nemi Chand Nai Aged 38 Years Resident Of
Gaudapada Naiyo ka Chouk Kishanghat Ki Prol darjipada
District Jaisalmer- 345001
72. Poonam Kumari D/O Girraj Prasad Aged 28 Years Resident
Of JP Nagar (Meena Colony) Delhi Road Tehsil Alwar District
Alwar – 301001
73. Pradeep Verma S/O Magni Ram Verma Aged 46 Years
Resident Of 53,54,55 Gali No 14 Sanganer Colony Bhilwara
District Bhilwara-311011
74. Om Prakash Gotam S/O Raja Ram Gotam Aged 38 Years
Resident Of H No 197 Dream Lalnd Colony Hanumangarh
75. Deepak Kumar S/O Desh Raj Aged 33 Years Resident Of
Ward No 04 Naw Khunja Hanumangarh Junction District
Hanumangarh -335512
76. Akashdeep Joshi S/O Shriram Joshi Aged 34 Years Resident
Of H No 196 Sector No 11 A Ward No 08 Hanumangarh
in the above case do hereby make, constitute and appoint.
Shri Tanveer Ahamad, Advocate,
R/2303/2003
Mobile no. 9829604104
my/ our true and lawful attorneys, for me/us in my/our name, and on my/our behalf to appear
plead and act in the said case, and more particularly to draw, make, present, withdraw, amend,
represent and verify petition, plaints or written statements and to make, present applications or
petitions in the court, to present withdraw and receive documents and any money from the Court or
from the opposite party either in execution of the decree or otherwise, and on receipt of payment
thereof to sign and deliver for me/us proper receipts and discharges for the same, to compromise or
to refer the case to arbitration, to seek execution of the decree or any orders in the case, to draw,
make present, withdraw, amend and represent any memorandum of appeal or cross objections in
any appeal arising or to seek reviews or revision of any Judgment, decree or order in the case, to
appear, conduct and plead in all such writ / appeals / revisions and reviews, and to do all other
lawful acts and things as effectually as I/we could do the same whether being personally present or
otherwise, My/ our said counsel is/are also hereby authorized and empowered to instruct, engage or
appoint any other counsel or counsels to appear, plead and act with or for him/them in his/their
absence or otherwise as my/our said counsel may think proper to do so, all acts of such counsel or
counsels shall be equally and similarly binding on me/us as if done be my/our said counsel and as
if done by me/us personally.
I/We hereby agree that if any part of the said counsel's fee remains unpaid before the first
hearing of the case, or if any hearing of the case be fixed on tour or at any other place except the
usual court premises, then my/our said counsel will not be bound to appear before the court. The
counsel's fee now settled and agreed to is in respect of this Court and for the pending proceedings
only. Any fresh action hereafter taken will entitle the counsel to fresh fees. I/We also agree that if the
case be dismissed in default or if it be proceeded ex-parte under any circumstances whatsoever the
said counsel shall not be held responsible for the same and all whatsoever my/our said counsel
shall do in connection with the said case, I/We do hereby agree to ratify and confirm. Any costs
awarded in the case at any time in my/our favour shall form part of the counsel's claim and shall be
payable to him /them in addition to his/their fees in the case.
IN WITNESS WHEREOF I/we have hereto set my/our hand (s) at
____________________this____________________day of _____________________ and delivered to the said
counsel (S)

Versus
(1) SERVICE MATTERS
“A” APPOINTMENT / RECRUITMENT / PROMOTION
DEPARTMENT POST SUBJECT MATTER

(Ground of Writ e.g. Age,
Bonus Marks, Eligibility,
Reservation etc.)
Department of Junior the humble petitioners who are
Skill Instructors working for many years have
also become overage for regular
recruitment and it is also a fact
situation that the policy of the
State Government to impart
bonus marks for those who are
working and imparting similar
duties in different department
like for the post of Nursing
Department as also for the post
of Lab Technician, for the post of
Pharmacist etc. parting
education in the ITI and now
they will not be able to compete
with the fresh candidates, so the
benefit of bonus marks are also
required to be granted to the
petitioners for regular
recruitment, whenever the
(Tanveer Ahamad)
Advocate

Umesh Kumar Sharma & Ors. - Writ Petition - 02.08.2023

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Umesh Kumar Sharma & Ors. - Writ Petition - 02.08.2023

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IN THE HIGH COURT OF JUDICATURE FOR

RAJASTHAN JAIPUR BENCH AT JAIPUR

S.B. CIVIL WRIT PETITION NO. _________/2023

1. Umesh Kumar Sharma S/O Mohan Lal Sharma

S.B. WRIT PETITION UNDER ARTICLE 226

MAY IT PLEASE YOUR LORDSHIPS,

The humble petitioners, above named, most

1. That the petitioners are Citizens of India and the

may graciously be pleased to accept and allow this writ

1. The arrangement continued for engaging the

may be declared arbitrary and illegal and

2. The respondents may be directed to allow the

make salary of the all 12 months.

to the petitioner not to be replaced by another set of

The principle of last come first go may be directed to

4. Due to transfer of regular be selected persons the

discontinued and the respondents may be directed

available vacant post.

services of the petitioners also under the

under notification dated 11.01.2022.

experience certificate to the humble petitioners for

be ordered to be considered for the purpose of

and this policy may be directed to be formulated

7. The respondents may also be directed to provide the

essential qualification for the post of Junior

advertisement is issued by the State Government,

may also be equipped with the minimum eligiblity

8. Any other appropriate order, which may be found

the case, be passed in favour of the petitioners.

S.B. CIVIL WRIT PETITION NO. ________/2023

AFFIDAVIT IN SUPPORT OF WRIT PETITION

1. That I am one of the Petitioners in the above

2. That the annexed writ petition has been drafted by my

3. That the statements in the writ petition are true and

I, the above named deponent, do hereby verify that

S.B. CIVIL MISC. STAY APPLICATION NO……../2023

1. Umesh Kumar Sharma S/O Mohan Lal Sharma

S.B. CIVIL MISC. STAY APPLICATION

MAY IT PLEASE YOUR LORDSHIPS,

The humble petitioners-applicants above named,

1. That the petitioners have preferred annexed writ

2. That humble petitioners have a strong prima-facie

It is, therefore, humbly prayed that this stay

the respondents may be directed to allow the humble

S.B. CIVIL MISC. STAY APPLICATION NO……../2023

AFFIDAVIT IN SUPPORT OF STAY APPLICATION

I, Umesh Kumar Sharma S/O Mohan Lal Sharma

1. That I am one of the Petitioners-Applicants in the

S.B. CIVIL WRIT PETITION NO. _______/2023