Gujarat High Court Upholds Minimum Pay Rights for Part-Time Worker After State’s Appeal Challenges Eligibility Clause

By Vivek G. • November 24, 2025

Deputy Director, Animal Husbandry & Anr. vs. State of Gujarat & Anr., Gujarat High Court dismisses State’s appeal, confirming that part-time employees working four hours or more must receive ₹14,800 fixed pay under the 2019 circular.

The Gujarat High Court on Monday dismissed a Letters Patent Appeal filed by the Deputy Director of Animal Husbandry, bringing a quiet but significant moment in a packed courtroom where even the lawyers seemed to sense that the bench wasn’t inclined to interfere with the earlier decision. The case revolved around the interpretation of a 2019 government circular that fixed monthly pay for part-time workers serving four hours or more.

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Background

The dispute began when a part-time employee claimed entitlement to a fixed pay of ₹14,800 per month under the Circular dated 16 July 2019. The Single Judge had earlier directed authorities to verify his working hours and, if he indeed worked four hours or more, grant him the benefits.

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The State authorities were unhappy with this and argued in appeal that only those working more than four hours qualified - not exactly four. Interestingly, they also relied on a previous 2023 judgment where the High Court clarified that employees working less than four hours cannot claim this benefit.

Court’s Observations

In the hearing, Justice A.S. Supehia, speaking for the bench, cut through the confusion that the State seemed to persist with. “The contents of the circular are self-explanatory,” the bench observed, noting that the government had merged earlier wage categories and declared a fixed ₹14,800 salary for those working four hours or more.

The employee in this case, the bench noted, was admittedly working four hours daily - a fact the State could not dispute.
The judges emphasised that interpreting the circular to include workers who served less than four hours would lead to absurd outcomes.

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As the bench put it, “If construed otherwise, even someone working for a few minutes would be eligible. That cannot be the intention of the State Government.”

The bench reaffirmed that part-time employees who render actual four hours of service are eligible for the fixed pay, and the employer is free to conduct verification - nothing more, nothing less.

Decision

Finding no error or illegality in the Single Judge’s ruling, the Division Bench dismissed the appeal and disposed of the connected civil application. With this, the directions issued earlier - verify the working hours and grant benefits if found eligible - stand undisturbed.

Case Title: Deputy Director, Animal Husbandry & Anr. vs. State of Gujarat & Anr.

Case No.: Letters Patent Appeal No. 1197 of 2025

Case Type: Letters Patent Appeal (LPA) arising from Special Civil Application

Decision Date: 03 November 2025

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