Administrative action entailing civil consequences must comply with principles of natural justice and audi alteram partem.

The petitioners were initially appointed as daily wage employees in various government colleges across Madhya Pradesh.

Under the State’s Viniyamitikaran policy (Circular dated 07.10.2016), they were granted the status of permanent employees (Sthayi Karmi) in various categories (Skilled/Unskilled) by an order dated 06.02.2024.

Subsequently, the Additional Secretary of Higher Education and college authorities issued impugned orders dated 24.10.2025 and 28.10.2025, which cancelled the petitioners' Sthayi Karmi status based on internal communications from 2023.

The petitioners challenged these orders on the grounds that they were issued without a show-cause notice or an opportunity for a hearing, violating the principles of natural justice.

1. Whether the administrative orders withdrawing the Sthayi Karmi status from the petitioners are legally sustainable given that they were passed without affording an opportunity of hearing.

2. Whether the controversy regarding the applicability of the 07.10.2016 Circular to employees of Janbhagidari Samitis/Autonomous Colleges is already settled by prior judicial precedents.

The Court primarily applied the principle of Audi Alteram Partem, a fundamental facet of natural justice which stipulates that no person shall be condemned unheard.

The rule of audi alteram partem applies to all administrative actions involving civil consequences as held in State Bank of India v. Rajesh Agarwal (2023) 6 SCC 1.

Precedent set by a Coordinate Bench in W.P. No. 14044 of 2018, affirmed by the Division Bench, which addressed the rights of daily wagers under the 07.10.2016 Circular.

The Court observed that the petitioners had already transitioned from daily wagers to Sthayi Karmis and were receiving the associated pay scales and benefits.

The withdrawal of such status constitutes an administrative action with "serious civil consequences," thereby necessitating a pre-decisional hearing.

The Court found it undisputed that the respondents failed to issue show-cause notices or provide any hearing before passing the cancellation orders.

The Court determined that the impugned action was a "gross violation of the principles of natural justice."

The court noted that the parent Circular dated 07.10.2016 remains in force and that the respondents’ reliance on internal withdrawal orders did not bypass the need for due process.

The High Court allowed the writ petitions and set aside the impugned orders dated 24.10.2025 and 28.10.2025.

The Court granted liberty to the respondents to proceed afresh, directing them to: (i) issue detailed show-cause notices to the petitioners; (ii) provide a reasonable opportunity of hearing; and (iii) pass a reasoned and speaking order in light of the judgment in W.P. No. 14044 of 2018.