This technical note proposes a framework for the observer design for networked control systems (NCS) affected by disturbances, via an emulation-like approach. The proposed model formulation allows us to consider various static and dynamic time-scheduling protocols, in-network processing implementations and encompasses sampled-data systems as a particular case. Provided that the continuous-time observer is robust to the measurement errors (in an appropriate sense) we derive bounds on the maximum allowable transmission interval that ensure the convergence of the observation errors under network-induced communication constraints. The stability analysis is trajectory-based and utilizes small-gain arguments. A number of observers can be combined and used within our approach to obtain estimators for NCS.