Sports Authority of India Ordered to Regularize Physiotherapists: Supreme Court Dismisses Appeals

The Supreme Court of India recently delivered a significant ruling in the case of Sports Authority of India & Anr. vs. Dr. Kulbir Singh Rana. The case involved the regularization of physiotherapists who were initially appointed on a contractual basis by the Sports Authority of India (SAI). The Supreme Court upheld the judgment of the Central Administrative Tribunal (CAT) and the Delhi High Court, directing SAI to consider these employees as initial constituents of the organization under the Sports Authority of India (Executive Cadre) Staff Recruitment Rules, 2022.

Background of the Case

The Sports Authority of India (SAI) was created in 1984 as a society under the Societies Registration Act, 1860, to promote sports and games in India. Recruitment and employment regulations within SAI were governed by two sets of rules:

The Sports Authority of India (Sports Sciences and Sports Medicine) Staff Recruitment Rules, 1992.
The Sports Authority of India (Executive Cadre) Staff Recruitment Rules, 2022.

The 2022 Rules introduced a provision for initial constitution, which allowed existing employees on an ad-hoc basis to be deemed as regular employees upon approval by a screening committee.

The respondent, Dr. Kulbir Singh Rana, was appointed as a physiotherapist (Grade II) on a contractual basis in 2021. However, when SAI restructured its cadre in 2022 and advertised fresh vacancies, the respondent’s name did not appear in the list of selected candidates. As a result, he challenged the decision before the Central Administrative Tribunal (CAT).

Central Administrative Tribunal (CAT) Ruling

The CAT ruled in favor of the respondent on November 4, 2023, stating that:

The respondent was recruited through an open selection process and possessed the required qualifications.
His appointment was not illegal but merely irregular.
Under the initial constitution clause in the 2022 Rules, he should be deemed a part of the permanent workforce of SAI.
SAI was directed to consider his case for regularization within eight weeks.
Termination orders issued against him on February 9-10, 2023 were quashed.

Delhi High Court Decision

SAI challenged the CAT’s order before the Delhi High Court, but during the proceedings, the counsel for SAI conceded that they would comply with the order and sought additional time. The High Court, in its order dated February 28, 2024, granted SAI an eight-week extension to implement the CAT’s ruling.

However, SAI later filed recall applications before the High Court, arguing that their counsel had misunderstood the order and that they never intended to accept the Tribunal’s decision. The High Court dismissed the recall applications, stating:

“A party cannot turn back and challenge an order once passed on concession, unless there is fraud or deception.”

Following this, SAI filed an appeal before the Supreme Court.

Arguments Before the Supreme Court

Arguments by SAI (Appellant):

The High Court misinterpreted the initial constitution provision of the 2022 Rules.
Employment under ad-hoc or contractual terms does not automatically entitle an employee to regularization.
The organization was undergoing a cadre restructuring, and all contractual employees were required to reapply.

Arguments by the Respondent (Dr. Kulbir Singh Rana):

The respondent had worked continuously as a physiotherapist and was hired through a competitive process.
SAI had already accepted before the High Court that the respondent was eligible for consideration under the initial constitution clause.
The termination of the respondent was unjustified, as he met all qualifications for regularization.

Supreme Court’s Observations and Ruling

The Supreme Court upheld the High Court and CAT’s decisions, stating:

The initial constitution provision in the 2022 Rules was designed to ensure continuity of service for existing employees.
SAI had itself conceded before the High Court that the respondent’s case would be considered.
Since the respondent was appointed through a proper selection process and met the required qualifications, he could not be arbitrarily removed.
The recall applications filed by SAI were without merit, as they failed to provide a legitimate reason for reversing their previous stance.

“Once an organization makes a concession in court regarding an employee’s eligibility, it cannot later reverse its position without just cause.”

Accordingly, the Supreme Court:

Dismissed SAI’s appeal.
Ordered SAI to regularize the respondent as per the 2022 Rules.
Quashed the termination orders issued against the respondent.

Key Takeaways from the Judgment

Employees appointed through due process cannot be arbitrarily terminated during cadre restructuring.
The initial constitution clause in service rules must be interpreted in a manner that protects employees from unjust termination.
A party cannot resile from a concession made in court unless there is evidence of fraud or coercion.
Judicial orders enforcing labor rights and employment continuity should be respected and implemented in good faith.

Conclusion

The Supreme Court’s judgment in this case reinforces the principle of employment security in government organizations. It underscores the importance of adhering to service rules and prevents organizations from arbitrarily dismissing employees under the pretext of restructuring. The ruling sets an important precedent for contract employees in public institutions seeking regularization.

Petitioner Name: Sports Authority of India & Anr..
Respondent Name: Dr. Kulbir Singh Rana.
Judgment By: Justice Sudhanshu Dhulia, Justice Ahsanuddin Amanullah.
Place Of Incident: New Delhi.
Judgment Date: 04-03-2025.

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