Bombay High Court

### Municipal Employees Are Not State Government Servants for Claiming Age Relaxation Under General Service Rules

Raju Dhondira Akrupe vs The State Of Maharashtra Thro The Principal Secretary Urban Development Dept.

Bombay High CourtJUDGMENT: July 15, 20263 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The four petitioners, currently employed in various government-related capacities (Food Safety Officer and Motor Vehicle Inspectors), applied for the post of Assistant Commissioner advertised by the Navi Mumbai Municipal Corporation (NMMC) on 13.12.2025

Source reference: p. 5-6

They challenged the advertisement on the grounds that it failed to provide an upper age relaxation for "Government Servants"

Source reference: p. 2

The petitioners argued that Note 3B of Rule 7 of the Bombay Civil Services Rules, 1939 (saved by subsequent 1959 and 1981 Rules), exempted government servants from upper age limits for recruitment by nomination

Source reference: p. 3-4

They further contended that NMMC Service Rules 2021 (Rule 5.4) mandated following State Government age limit policies

Source reference: p. 7

The Respondents (State and NMMC) argued that Municipal Corporation employees are distinct from State Government employees and are governed strictly by the NMMC Service Rules 2021

Source reference: p. 10-11
02

Issues

1. Whether the upper age relaxation for government servants under Rule 10 of the Maharashtra Civil Services (General Conditions of Services) Rules, 1981, and the 1939 Rules is applicable to recruitment processes conducted by the Navi Mumbai Municipal Corporation

Source reference: p. 2 / para. 3

2. Whether the action of Respondent No. 2 in not incorporating an age relaxation clause for government servants in the advertisement dated 13.12.2025 is illegal or unconstitutional

Source reference: p. 2 / para. 1(b)
03

Law Applied

The Court primarily applied Rule 10 of the Maharashtra Civil Services (General Conditions of Services) Rules, 1981, which prescribes age limits for entry into State Government service

Source reference: p. 5, 11

It also considered Rule 5.4 of the Navi Mumbai Municipal Corporation Services (Recruitment to Services and Classification of Services) Rules, 2021, which sets the minimum age at 18 and leaves the maximum age to be governed by prevailing government resolutions and specific corporation policies

Source reference: p. 13-14

The Court relied on the legal distinction that Municipal Corporation employees do not fall under the category of "State Government Servants" as defined for the purpose of the 1939 or 1981 Civil Service Rules

Source reference: p. 11
04

Reasoning

The Court reasoned that while Rule 5.4 of the NMMC Rules 2021 refers to prevailing State Government rules for maximum age limits, this does not automatically transplant the specific "government servant" exemptions from the 1981 Rules into Municipal recruitment

Source reference: p. 13

Relying on the State's affidavit, the Court observed that the Finance Department had clarified that Municipal Corporation employees are not State Government employees; therefore, they are governed by the NMMC-specific service rules rather than the general Maharashtra Civil Services Rules

Source reference: p. 11

The Court found that NMMC Service Rules are "self-sufficient" regarding age limits

Source reference: p. 13

Since the petitioners were seeking a post within a Municipal Corporation, they could not claim a statutory right to age relaxation designed specifically for those within the State Government’s direct cadre

Source reference: p. 15

The Court concluded that the NMMC was within its rights to issue an advertisement without the contested relaxation clause

Source reference: p. 15
05

Holding

The Court held that the petitioners are not entitled to age relaxation as a matter of right because the Rules of 1939 and 1981 do not apply to Municipal Corporation recruitment

The Court directly answered that Municipal Corporation employees are not Government Servants for the purpose of the 1981 Rules

Source reference: para. 11, 14

Consequently, the advertisement dated 13.12.2025 was declared perfectly valid

Source reference: para. 17

The Writ Petition was dismissed, and no costs were awarded

Source reference: p. 15
Bombay High Court

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Raju Dhondira AkrupevsThe State Of Maharashtra Thro The Principal Secretary Urban Development Dept.

Bombay High Court · July 15, 2026

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