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Issues Involved:
1. Representation and Absorption of Trainee Engineers 2. Regularization and Seniority of Appellants 3. Application of Promissory Estoppel Summary: 1. Representation and Absorption of Trainee Engineers: The Bihar State Electricity Board advertised for the selection of Electrical Engineers under an "Employment Promotion Programme" in 1975, requiring 50% marks in the degree examination. Selected engineers, termed Apprentice Engineers or Trainee Engineers, were called for six months of training starting April 1, 1977. Despite the Board's initial indication that training did not guarantee employment, it later resolved in August 1977 to fill 200 vacant Junior Engineer posts and continue existing trainees on stipends. The Board assured regular employment post-training, leading trainees to forego other opportunities, but failed to implement these decisions. The High Court dismissed writ petitions challenging the continuity of trainee engineers, leading to the present appeals. 2. Regularization and Seniority of Appellants: The Board's notice on March 13, 1979, promised regular appointments for degree and diploma trainees post-training in October 1979. Despite this, the Board did not implement the decision, causing engineers to serve on an ex cadre basis. The Board's negative approach led to the appellants seeking a High Court directive for encadrement, which was denied. The Supreme Court noted that the Board had repeatedly assured absorption without further examination and had taken advantage of the trainees' services during strikes. The Court directed the Board to offer regular appointments within three months from May 3, 1985, with a two-year probation period. The appellants were to rank below pre-1983 recruits but above those recruited during the pendency of the appeals. 3. Application of Promissory Estoppel: The Court emphasized the doctrine of promissory estoppel, stating that public bodies must honor representations made, especially when individuals have relied on them to their detriment. The Board, being a statutory authority and 'State' u/s Article 12 of the Constitution, could not evade its obligations under the equitable doctrine. The Court cited precedents like Union of India v. Indo-Afghan Agencies and Century Spinning & Manufacturing Co. Ltd. v. Ulhasnagar Municipal Council, reinforcing that public bodies must act in good faith and uphold promises made to citizens. Conclusion: The Supreme Court allowed the appeals, reversed the High Court's judgment, and mandated the Board to regularize the appellants' appointments within the specified timeframe. The Board was cautioned against future conduct that could lead to similar legal challenges. The appellants were awarded costs throughout, with a hearing fee of Rs. 5,000 in the Supreme Court.
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