(1.) Heard Mr. R.K. Ojha, learned Senior Counsel, assisted by Mr. Yash Singhal, learned counsel for the petitioner, Mr. Ashok Khare, learned Senior Counsel, assisted by Ms. Srishti Gupta, learned counsel for respondent no.3 and Mr. Ashish Kumar Nagvanshi, learned counsel for the State- respondents.
(2.) The writ petition has been filed with the following prayers:-
(3.) Placing the brief facts of the case, learned counsel for the petitioner submits that petitioner was appointed as an Assistant Teacher of Hindi, (Primary) on 1/7/1991, on a contractual basis, in an Institution, namely, St. Joseph's Girls Junior High School, Civil Lines, Moradabad, (in short 'the institution'), which is a minority Institution established under Article 30(1) of the Constitution of India. The contract of the petitioner was renewed from time to time and was operative without any time gap. The Institution in question came into grant-in-aid list in the year 2015, accordingly, appointments were made in the Institution and the petitioner was issued appointment letter on 26/6/2015. The petitioner took charge as an Assistant Teacher (Hindi) on 1/7/2015 before the Manager of the Institution, an experience certificate has been issued to the petitioner by the Government aided Institution, mentioning that the petitioner has been continuously working in the primary wing and was thereafter appointed in the Junior department as Assistant Teacher (Hindi) on 1/7/2015, thus, it clearly transpires from the experience certificate that the petitioner had been regularly working from 1991 till 2015, and thereafter she was appointed as an Assistant Teacher in the aided Institution.