M.P. HOUSING BOARD vs MANOJ SHRIVASTAVA

The Supreme Court held that under Section 31(3) and Section 64-A of the Madhya Pradesh Industrial Relations Act, 1960, a daily wage employee can be classified as permanent if they have satisfactorily completed six months of service. The Court affirmed the Labour Court's decision to categorize the Respondent as a permanent employee despite the absence of a sanctioned post, emphasizing that satisfactory service is a valid ground for regularization. The appeal by the Appellants was dismissed, upholding the lower court's ruling.