Courts Will Not Interfere in Administrative Decisions Regarding Relocation of Public Health Centers

The petitioners, residents of Village Neelkanth, filed this Public Interest Litigation (PIL) challenging the relocation of a sanctioned Sub-Health Centre from Village Neelkanth to Village Bhulganv.

Initially, the health center was sanctioned for Neelkanth on 20.03.2025 based on population and geographical needs.

The petitioners alleged the shift to Bhulganv was arbitrary, politically motivated, and ignored the fact that the proposed site at Bhulganv was unsuitable (encroached/marshy) while Village Neelkanth was centrally located.

This is the second round of litigation; in the first (WP No. 41267/2025), the Court directed the Collector to decide on the petitioners' representation.

The Collector rejected the representation on 13.11.2025, maintaining the relocation.

1. Whether the administrative decision to relocate the Sub-Health Centre from Village Neelkanth to Village Bhulganv was arbitrary, mala fide, or violative of Articles 14 and 21 of the Constitution of India.

2. Whether the High Court, under Article 226, can interfere with a purely administrative decision regarding the location of public health facilities.

Interpretation of the scope of judicial review under Article 226 of the Constitution of India, which limits interference in "purely administrative decisions" unless they are perverse or lack jurisdiction.

Application of Directive Principles of State Policy, specifically Articles 38, 39(e), and 47, concerning the State's duty to provide healthcare, balanced against executive discretion.

The Court examined the State's justification for the relocation, noting that the decision was not arbitrary but based on "administrative feasibility, population distribution, accessibility, safety, and availability of suitable land".

The Court found that the Chief Medical and Health Officer and the Sub-Engineer had submitted factual reports confirming the suitability of the Bhulganv site.

The relocation was scrutinized and approved by higher authorities, including the Directorate of Public Health and Medical Education and the National Health Mission (NHM) under the 15th Finance Commission Scheme.

The Court dismissed the petitioners' claims of political interference, concluding that since the decision was approved by the NHM and followed standard administrative procedures, it did not warrant judicial intervention.

The Court answered the issues in the negative, finding no grounds for interference under Article 226.

Consequently, the Writ Petition was dismissed.