Salary cannot be withheld without authority of law as it constitutes property under Article 300-A.

The petitioners are assistant teachers, junior clerks, and peons appointed in various private aided schools in Maharashtra between 2009 and 2017. Their appointments were duly approved by the Education Officer (Primary), and they were subsequently allotted "Shalarth IDs" to facilitate salary payments via the state’s digital system

In March 2025, the respondent authorities abruptly stopped the petitioners' salaries and cancelled their approval orders and Shalarth IDs without prior show-cause notices or departmental inquiries

The respondents alleged irregularities in the grant of approvals and flaws in the digital records (UDISE+ and outward registers) discovered during a "hasty" mass review

The petitioners challenged these actions as arbitrary and violative of the principles of natural justice and Article 14 of the Constitution.

The court primarily applied the principle that salary is "property" under Article 300-A of the Constitution, which cannot be deprived without authority of law

It relied on Mohinder Singh Gill v. Chief Election Commissioner, holding that statutory orders must be judged by the reasons mentioned therein and cannot be supplemented by fresh reasons in affidavits

The court followed the precedent in Shivanee Prasanna Deshpande v. State of Maharashtra, which establishes that approvals granted by the Education Officer cannot be recalled unless fraud or misrepresentation is strictly proven

Additionally, it applied Government Resolution (GR) dated 10/06/2022, which mandates a detailed inquiry involving the management and the officer who granted the original approval before taking adverse action

The Court observed that the petitioners had rendered 10 to 15 years of continuous service, during which their approvals were never questioned by annual inspections

The Court found that the respondents conducted a "farce" inquiry by calling 150 teachers on a single day to fill out forms without granting personal hearings, which failed the test of natural justice as articulated in H.L. Trehan v. Union of India

The Court highlighted that the show-cause notices were vague and lacked specific details of any fraud committed by the individual petitioners, which is a prerequisite for cancelling long-standing approvals

Furthermore, the Court noted that the department failed to summon the Education Officers who originally granted the approvals, violating its own GR dated 10/06/2022

The Court concluded that systemic flaws in the Pavitra Portal or UDISE+ and clerical errors in outward registers (e.g., mismatched dates) are not attributable to the teachers and cannot form the basis for withholding pay

It held that denying pay for service rendered amounts to "forced labour" and is impermissible

The Court directed the respondents to restore the petitioners' Shalarth IDs and release all withheld salaries since March 2025 immediately [p. 121]. While setting aside the orders, the Court granted the authorities liberty to issue fresh, specific show-cause notices only in cases involving fraud or misrepresentation, provided they follow prescribed legal procedures [p. 120]. The prayer to stay the operation of the judgment was rejected