Bombay High Court
THE STATE OF MAHARASHTRA THROUGH SECRETARY MEDICAL EDUCATION AND DRUGS DEPARTMENT MANTRALAYA MUMBAversusDR Aradhana Arvind Deshmukh
- Disposal
- DISPOSED OFF
Holding
An ad‑hoc appointment made after a proper selection process does not amount to a back‑door entry.
Summary
The State of Maharashtra filed a writ petition challenging the appointment of Dr. Aradhana Arvind Deshmukh as an Assistant Professor on an ad‑hoc basis. The petition alleged that the appointment was a back‑door entry and sought regularisation of the post. The High Court referred to its earlier decision in Nagpur Bench (Writ Petition No.154 of 2025) which held that ad‑hoc appointments made after a proper selection process are not back‑door entries. The court observed that the respondents’ services were to be regularised only after they become permanent, and the initial entry was through a legitimate selection by the Divisional Selection Board. Relying on that precedent, the court found no merit in the present petition and dismissed it. The order was pronounced by Justices N. B. Suryawanshi and Vaishali Patil‑Jadhav.
Issues considered
- Whether the ad‑hoc appointment of the respondent as Assistant Professor constitutes a back‑door entry in violation of appointment rules.
Subjects
- ad‑hoc appointment
- assistant professor
- selection board
- back‑door entry
- permanent regularisation
- writ petition
Judgment
2026:BHC-AUG:14722-DB
1
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
BENCH AT AURANGABAD.
925 WRIT PETITION NO.6089 OF 2025
The State of Maharashtra
Through the Secretary, Medical Education And
Drugs Department Mantralaya Mumbai & Others ..Petitioners
Versus
Dr Aradhana Arvind Deshmukh ..Respondent
…..
Shri. S. R. Wakle, AGP for the Petitioner – State.
Shri. M. R. Kulkarni, Advocate for the Respondent
…..
CORAM : N. B. SURYAWANSHI AND
VAISHALI PATIL – JADHAV, JJ.
Dated : APRIL 02, 2026
FINAL ORDER :-
. Undisputedly, the challenge raised in the present Petition is
squarely covered by the decision of this Court (Coram : Nitin W. Sambre
and Mrs. Vrushali V. Joshi, JJ.) at Nagpur Bench, in Writ Petition No.154
of 2025 with connected Petitions rendered on 9 th May, 2025. In the said
decision, the Court considered the challenge raised to the common
judgment, similar to the one raised in the present Petition and held as
under:
‘17. We have considered the rival claims. The admitted
position on facts is that till the services of the respondents are
regularized or made permanent as an Assistant Professor, all
the respondents were working on the said post on ad hoc
basis pursuant to their selection by the Divisional Selection
Board. As such, there is a reason to believe that the initial
entry of the respondents was after undergoing the selection
process and the same cannot be in any case terms as a back-
2
door entry.’
2. In view of the reasons recorded in the aforementioned order, we
see no merit in the Petition and the same is, accordingly, dismissed.
(VAISHALI PATIL-JADHAV, J.) (N. B. SURYAWANSHI, J.)
GGP
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