Chhattisgarh High Court

### Nominee status and succession certificate for government dues do not qualify as legal heirship for compassionate appointment.

Rajani Dewangan v. State of Chhattisgarh & Others [2026:CGHC:11597]

Chhattisgarh High CourtJUDGMENT: no citation2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, Rajani Dewangan, applied for compassionate appointment following the death of Mem Bai Dewangan on March 22, 2017, who was serving as a Peon at a Government Primary School

Source reference: para. 2

The deceased was unmarried and had named the petitioner as her nominee in service records for government dues

Source reference: para. 2, 7

Based on this, the Additional Collector issued a succession certificate to the petitioner for claiming benefits

Source reference: para. 2

However, the respondent authorities rejected the petitioner’s application for compassionate appointment on May 27, 2019, citing Clause-6 of the State circular dated June 14, 2013

Source reference: para. 1

The petitioner challenged this rejection, claiming status as an adopted daughter

Source reference: para. 3, 7
02

Issues

1. Whether the petitioner, as a nominee/claimed adopted daughter of an unmarried deceased government servant, is eligible for compassionate appointment under the policy prevailing in the State of Chhattisgarh

Source reference: para. 6, 8
03

Law Applied

The court primarily applied Clause-6 of the State Government Circular dated June 14, 2013, which stipulates that in the event of the death of an unmarried government servant, the entitlement for compassionate appointment extends only to the brother or unmarried sister of the deceased, provided there is a recommendation from the parents

Source reference: para. 1, 6

The court further applied the principle that a succession certificate issued for the purpose of collecting government dues does not confer a right to seeking employment

Source reference: para. 8
04

Reasoning

The court observed that the deceased employee was admittedly unmarried

Source reference: para. 7

Under the governing circular of 2013, eligibility is strictly restricted to the siblings of the deceased

Source reference: para. 6

Although the petitioner claimed to be an adopted daughter, the court found no documentary evidence on record to prove a legal adoption

Source reference: para. 7

The court noted that the petitioner’s name appeared in the service records only as a "nominee," and the succession certificate granted by the Additional Collector was explicitly limited to the collection of government dues and benefits, not for establishing a relationship sufficient for compassionate appointment

Source reference: para. 2, 8

Consequently, the petitioner did not fall within the defined categories of "brother or sister" as required by the policy

Source reference: para. 8
05

Holding

The Court held that the application for compassionate appointment was rightly rejected by the authorities as the petitioner failed to meet the criteria set out in Clause-6 of the circular dated June 14, 2013

The Court found no merit in the petition and dismissed it

Source reference: para. 9
Chhattisgarh High Court

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Rajani Dewangan v. State of Chhattisgarh & Others [2026:CGHC:11597]

Chhattisgarh High Court · no citation

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