Facts
The petitioners filed a writ petition under Article 226 challenging the order dated 26 May 2025, which stopped grant-in-aid to the institution in which they served.
Source reference: para. 1They submitted that the controversy had already been decided in Munnalal and Others v. State of M.P. and Others, W.P. No. 5963/2026, decided on 16 September 2026.
Source reference: para. 2The State was unable to distinguish the present case from Munnalal.
Source reference: para. 3After considering that decision, the Court disposed of this petition on the same terms, applying its directions mutatis mutandis.
Source reference: paras. 5–6Issues
Whether the order dated 26 May 2025 stopping grant-in-aid could stand in light of the Court’s decision in Munnalal.
Source reference: paras. 2–6Whether the petitioners were entitled to salary for any period during which they had actually worked.
Source reference: para. 7Law Applied
Article 226 empowers the High Court to grant relief where an administrative order is legally flawed. Rule 16(A) of the Grant-in-Aid Rules, 1985 permits the grant-in-aid authority to stop or reduce grant, or order recovery, where an aided institution fails to satisfy the authority regarding compliance with the Rules; the authority must first give notice specifying the defect and an opportunity to remedy it.
Source reference: para. 5, quoting Munnalal, paras. 15–16As applied in Munnalal, the mere existence of other schools nearby was not a ground under the 1985 Rules for stopping grant-in-aid, and a fresh decision required proper notice and an opportunity of hearing.
Source reference: para. 5, quoting Munnalal, paras. 17–20Reasoning
The State did not distinguish the facts from those in Munnalal, where the Court had held that grant-in-aid could not be stopped on a ground outside the 1985 Rules and had required the Collector to issue proper notice, consider the institution’s response and documents, and pass a fresh order after hearing it.
Source reference: paras. 3, 5The Court therefore applied the Munnalal directions mutatis mutandis to the present petition.
Source reference: para. 6It separately directed payment of salary for any period in which the petitioners had actually worked.
Source reference: para. 7Holding
The petition was disposed of on the same terms and conditions as Munnalal, with its directions applying mutatis mutandis.
The respondents were directed to pay the petitioners’ salary if they had actually worked during the relevant period.
Source reference: para. 7Pending interlocutory applications, if any, were also disposed of.
Source reference: para. 8Original Court PDF
Arvind Kumar GuptavsThe State Of Madhya Pradesh
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