At this juncture, the analogy of apples and oranges serves as a useful reminder that certain relationships are inherently incapable of being assessed on an equal plane. A contract between State and an employee stands on a similar footing. State, in such a relationship, assumes the role of a metaphorical lion, endowed with overwhelming authority, resources and bargaining strength, whereas an employee, who is yet an aspirant, is reduced to the position of a metaphorical lamb, possessing little real negotiating power. In such situations, the conscience of Constitutional Courts must inevitably tilt in favour of protecting the lamb.

– Hon’ble Justice Vikram Nath, Bhola Nath v. State of Jharkhand, [Special Leave Petition (Civil) No. 30762 of 2024].

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Bhola Nath v. State of Jharkhand, 2026 INSC 99 reiterated, State, as a model employer, bears a heightened constitutional obligation in discharge of its functions. It must act with probity, fairness and candour, and cannot cloud disputes involving its employees under narrow technical grounds divorced from their broader constitutional context. A model employer is expected to uphold dignity of its employees more so who are at the lowest pedestal of the hierarchy and to avoid exploiting their vulnerability or precarious position.

– Hon’ble Justice Sandeep Mehta, Sukhendu Bhattacharjee v. State of Assam, [Civil Appeal No. 4514 of 2025] decided on 21.05.2026.