01Facts
The petitioner was appointed as an Anganwadi Helper in 2007 and served for approximately 17 years.
¶ 2Following an incident on 27 June 2024 in which she was alleged to have obstructed and attempted to strike a Circle Supervisor, and amid earlier concerns about attendance and cleanliness, she received a show-cause notice, submitted a reply and was heard personally.
¶ 2The Project Officer terminated her services on 7 August 2024, with approval of the Sub-Divisional Officer.
¶ 2The appellate authority dismissed her appeal on 23 October 2024, relying, among other things, on video evidence.
¶ 2The petitioner sought judicial review of both orders.
¶ 202Issues
i.1. Whether the appellate order affirming the petitioner’s termination suffered from illegality, arbitrariness or procedural irregularity warranting interference under Article 226
¶ 6ii.2. Whether the show-cause process, consideration of the petitioner’s reply and personal hearing satisfied the required principles of natural justice
¶ 8–903Law Applied
The Court applied the principles governing judicial review under Article 226: it does not ordinarily substitute its assessment for that of the competent authorities, and interference is warranted where an order is contrary to law, unsupported by relevant material, perverse or passed in violation of prescribed procedure.
¶ 10It also considered the requirement of procedural fairness, including notice and an opportunity to respond, and observed that length of service or sympathy alone does not justify setting aside an otherwise lawful order.
¶ 8–9No specific statute or precedent was identified in the judgment.
04Reasoning
The Court found that the authorities had issued a show-cause notice, considered the petitioner’s explanation, granted her a personal hearing and obtained the competent authority’s approval before termination.
¶ 8–9The appellate authority had relied on video evidence concerning the alleged incident and considered the petitioner’s challenge; the Court also noted the record of earlier alleged irregularities.
¶ 6–7, 11The petitioner’s denial, expression of regret and lengthy service did not establish that the findings were unsupported or that the procedure was unlawful.
¶ 9–12As no specific procedural violation, perversity or other ground for judicial review was shown, the Court declined to interfere.
¶ 9–1205Holding
The Court answered the issues against the petitioner, holding that no illegality, arbitrariness, perversity or procedural irregularity warranting interference had been established.
¶ 11–12The writ petition was dismissed, leaving the termination order dated 7 August 2024 and appellate order dated 23 October 2024 undisturbed.
¶ 13Original Court PDF
Smt Manisha SharmavsThe State Of Madhya Pradesh
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